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"Clawback of Bonuses: UK PRA’s Banking Proposals Cast Six-Year Shadow for Bad Actors and Their Supervisors and Line Managers"

On 13 March 2014, the Prudential Regulation Authority (PRA), the U.K. regulator responsible for prudential supervision of banks, insurers and large broker-dealers, issued a consultation paper on bonus clawback (CP6/14). ...more

3/26/2014 - Bad Actors Clawbacks Corporate Bonuses Prudential Regulation Authority UK

"OECD Outlines Plans to Prevent Double-Tax Treaty Abuse"

On March 14, 2014, the Organisation for Economic Co-operation and Development (OECD) published a discussion draft report on preventing double-tax treaty abuse (the Treaty Report). The OECD supplemented this release on March...more

3/20/2014 - Double Taxation Fraud and Abuse OECD Tax Treaty

"UCITS V Gets EU Political Backing, Foreshadowing New Limitations on Manager Remuneration"

European lawmakers have reached agreement on amendments to the Undertakings for the Collective Investment in Transferable Securities (UCITS) Directive, which regulates the management and marketing of EU mutual funds. These...more

3/11/2014 - EU Financial Regulatory Reform Remuneration Transfers UCITS

"UK Banking Regulators and Foreign Banks: A Vision of Future Supervision"

The U.K.’s banking regulator, the Prudential Regulation Authority (PRA) recently published a consultation paper on its approach to supervising international banks (the Draft Supervisory Approach). ...more

3/7/2014 - Banks Foreign Banks Prudential Regulation Authority UK

"OECD Releases Global Standard for Automatic Exchange of FATCA-Type Information"

As part of a push for greater transparency, the Organization for Economic Cooperation and Development (OECD) released on February 13, 2014, a Common Reporting Standard (CRS) for Automatic Exchange of Financial Account...more

2/18/2014 - FATCA International Tax Issues OECD Reporting Requirements

"Base Erosion and Profit Shifting: Key UK Issues"

Six months have elapsed since the Organisation for Economic Co-operation and Development (OECD) released its 15-point action plan to address Base Erosion and Profit Shifting (BEPS). During this time, OECD has been working...more

1/22/2014 - BEPS Broadcasting Corporate Taxes G20 Multinationals OECD Telecommunications Transfer Pricing UK Value-Added Tax

"Taxpayer Naming – The Future of UK Tax Compliance?"

As part of Autumn Statement 2013, HM Revenue & Customs (HMRC) has today publicly named the banks that have newly adopted or readopted the Code of Practice on Taxation for Banks (the Code)....more

12/5/2013 - Banks EU HMRC Naming-and-Shaming UK

"UK Regulators Begin the Shake-Up of Asset Managers’ Use of Dealing Commission"

On 25 November 2013, the U.K.’s Financial Conduct Authority (the FCA) issued a consultation paper proposing new rules to clarify the circumstances in which U.K. asset managers can currently pay dealing commission (CP13/17)....more

12/2/2013 - Asset Management Broker-Dealer FCA Sales Commissions UK

"European Union Banking Reform Update"

By the end of this year, the European Commission will present its legislative proposals for EU banking structural reform. Once the proposals are implemented, EU banks will have to separate their “investment” business from...more

11/22/2013 - Banking Sector Capital Requirements EU European Commission Segregation Requirements UK Vickers Report Volcker Rule

"UK Government to Strengthen Code of Practice on Taxation for Banks"

On October 11, 2013, the U.K. Government announced three key changes to the Code of Practice on Taxation for Banks (the Code): - A bank that breaches the Code could be publicly named. However, before concluding whether...more

10/14/2013 - Bank Taxes Banks UK

"European Council’s Lawyers Opine That Proposed EU Financial Transaction Tax Is Unlawful"

The European Council Legal Service has issued an opinion that seriously questions the legal validity of the European Commission’s proposals for a financial transaction tax (FTT). The opinion finds that the extraterritorial...more

9/10/2013 - EU European Commission Financial Transaction Tax

"UK Government Considers Radical Changes to Approved Persons Regime"

The U.K. government recently published its response to the Parliamentary Commission on Banking Standards’ (the Commission) final report and recommendations, which partly cover the U.K.’s Approved Persons regime....more

7/25/2013 - Best Management Practices Criminal Prosecution Financial Conduct Authority Foreign Banks Managers Proposed Legislation Prudential Regulation Authority UK

"International Taxation – OECD Reboot for the 21st Century"

Introduction - Following on its February 2013 report on Addressing Base Erosion and Profit Shifting (BEPS), the Organisation for Economic Co-operation and Development (OECD) has now released an ambitious action plan...more

7/19/2013 - Corporate Taxes Income Taxes OECD Proposed Regulation Tax Evasion Tax Reform Tax Treaty

"UK Provides Marketing Grace Period for Alternative Fund Managers"

The U.K. Treasury recently published its response to its January 2013 consultation on transposing the EU Alternative Investment Fund Managers Directive (AIFMD). A revised draft version of the Alternative Investment Fund...more

6/25/2013 - AIFM AIFMD Disclosure Requirements EEA ESMA EU Financial Conduct Authority Marketing Private Equity Reporting Requirements

"HMRC Turns Up the Pressure on UK LLPs"

Following the announcement in Budget 2013, HM Revenue & Customs (HMRC) issued a consultation document on May 20, 2013 that focuses on two areas of partnership taxation where HMRC perceive “unintended inconsistencies”...more

5/22/2013 - AIFMD EU HMRC LLPs Lost Profits Partnerships Profits Tax Planning

"Shares for Rights: Over-Sold or Under-Appreciated?"

In this article we consider some alternative approaches to the proposed U.K. status of “employee shareholders,” who receive capital gains tax-exempt shares in their employer (or its parent) in return for waiving certain...more

5/14/2013 - Capital Gains Corporate Taxes Employee Shareholders EU Tax Exemptions Valuation

"UK Supreme Court: Legal Advice Privilege Relates to Lawyers’ Advice Only"

Summary - In an eagerly awaited decision of the U.K. Supreme Court in the case of R (on the Application of Prudential plc and Another) v. Special Commissioner of Income Tax and Another, [2013] UKSC 1, legal advice...more

1/25/2013 - Accountants Appeals EU Legal Advice Privilege

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