Paul Rutherford

Paul Rutherford

DLA Piper

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Brexit: How might taxes be affected? Key questions and answers on tax

What are the immediate tax consequences of the UK's vote to leave the EU in the so-called Brexit referendum?...more

6/29/2016

Brexit: What are the implications for tax law?

The precise impact of a Brexit on UK tax law is not possible to determine without knowing the terms of the exit negotiated by the UK with the EU and future government decisions. There are various ways the relationship between...more

6/24/2016 - BEPS Corporate Taxes Cross-Border Transactions Double Taxation EEA EU Free Trade Agreements Member State OECD Popular Referendums UK UK Brexit VAT

UK tax deductibility of corporate interest expense

The 2016 Budget announced, and the UK government is currently consulting on, the biggest change in UK tax this century. Up until 1st April 2017, a tax deduction for interest costs of up to 100% of UK profits is (very broadly)...more

6/15/2016 - Corporate Taxes Federal Budget Interest Payments Tax Deductions Tax Reform UK

UK Finance Bill 2016: Royalty Withholding Tax

Domestic UK law imposes a 20% royalty withholding tax on limited types of payment and on specific categories of intellectual property. This year's Finance Bill expands the scope of intellectual property royalties that are...more

5/16/2016 - BEPS License Agreements Royalties Tax Treaty UK Withholding Tax

Clampdown on VAT avoidance on sales of goods through online marketplaces

The Chancellor has announced a package of measures to give HMRC stronger powers to collect VAT from overseas businesses who sell goods online to UK customers. Failure to pay VAT in these circumstances is estimated to have...more

3/31/2016 - HMRC Internet Retailers UK VAT

UK Budget 2016: Finance

From April 2017, the UK government is to cap the amount of corporation tax relief for interest to 30% of taxable earnings in the UK or the net interest to earnings ratio for the worldwide group. This is subject to a threshold...more

3/21/2016 - BEPS Corporate Taxes Double Taxation OECD Tax Treaty UK

UK Budget 2016: IPT, technology and gambling

The Chancellor delivered his 2016 Budget yesterday. Below is a brief summary of the announcements which are relevant to corporates in the IPT sector....more

3/21/2016 - Corporate Taxes Gambling Royalties Tax Avoidance UK VAT

UK Budget 2016: Corporate tax and business transactions

This is a brief summary of some of the issues arising from the UK Budget 2016 which have an effect on corporate tax....more

3/18/2016 - Anti-Avoidance Corporate Taxes Employee Shareholders Entrepreneurs Net Operating Losses UK

UK Budget 2016: Real Estate

Yesterday George Osborne delivered the 2016 Budget. There were some significant announcements for the real estate industry....more

3/17/2016 - BEPS Foreign Investment OECD Real Estate Development Stamp Taxes UK

Brexit: What are the implications for tax law?

The precise impact of a Brexit on UK tax law is not possible to determine without knowing the terms of the exit negotiated by the UK with the EU and future government decisions. There are various ways the relationship between...more

3/16/2016 - Corporate Taxes Customs EEA EU Member State Trade Agreements UK UK Brexit VAT

Autumn Statement 2015 - Employment Tax Update

There are few proposals in the employment tax sphere in the Autumn Statement and even in relation to the proposals which have been announced, detail is lacking. In particular, HMRC's response to its consultation on changes to...more

12/1/2015 - Autumn Statement Employee Share Schemes Employment Tax HMRC UK

Autumn Statement 2015 - Real estate tax update

On 25 November the Chancellor delivered the 2015 Autumn Statement. From a real estate perspective, there were a few significant announcements. Stamp duty land tax (SDLT) Additional 3% on all bands on "additional"...more

11/30/2015 - Autumn Statement Capital Gains Real Estate Development Stamp Duty Land Tax UK

UK budget 2015

Earlier today the UK government delivered its last budget before the UK general election in May. Many of the measures were, as one might expect so close to an election, focused on personal rather than corporate taxation....more

3/24/2015 - Anti-Avoidance BEPS Corporate Taxes Diverted Profits Tax Employee Shareholders Entrepreneurs Federal Budget Financial Institutions GAAR Multinationals OECD Oil & Gas R&D Tax Credits Remuneration Research and Development Tax Credits UK Venture Capital Withholding Tax

Private Equity Tax Alert - What might the General Election bring

As we enter the run-up to the General Election in May, private equity funds and their managers might want to consider what the possible tax implications of a new Government might be both for the managers of their portfolio...more

2/18/2015 - General Elections Private Equity Private Equity Funds Tax Reform UK

EU patent box regimes - The way ahead

EU WITHDRAWS INVESTIGATION - Many countries in Europe, including the UK, The Netherlands, Belgium, Luxembourg, Spain, France and Hungary have special tax regimes for profits derived from specific types of intellectual...more

2/11/2015 - EU Patents The Patent Box

Diverted Profits Tax - What Arrangements May Be Caught?

BACKGROUND AND INTRODUCTION - The UK Government has announced the introduction of the Diverted Profits Tax (or 'DPT') - a new tax which will have effect from 1 April 2015. The tax is intended to target two types of...more

2/10/2015 - Corporate Taxes Diverted Profits Tax UK

Global Tax News - January 2015

A SWIFT LOOK AT OECD’S DISCUSSION DRAFTS ON BEPS PLUS ONE CHART SETTING OUT TIMELINES - During the short days before Christmas, when most of us were busy closing transactions or making last-minute year-end reviews to...more

1/31/2015 - BEPS Capital Gains CFC China Consolidated Tax Returns Corporate Taxes Equity Transactions EU Foreign Investment Foreign Subsidiaries France Google Google Tax Income Taxes International Tax Issues Italy OECD Russia Tax Credits The Patent Box UK

International Tax News - December 2014

UK WILL IMPOSE CAPITAL GAINS TAX ON NON-UK RESIDENTS - The UK government aims to go ahead with plans to impose capital gains tax on sales of residential property from April 2015. The government has published...more

12/16/2014 - Capital Gains Corporate Taxes Income Taxes UK

Diverted Profits Tax – First Thoughts

The UK Government intends to introduce a 25% “diverted profits tax” (DPT) from 1 April 2015. The tax is designed to catch the artificial erosion of the UK corporate tax base by multi-nationals that avoid establishing a...more

12/14/2014 - Corporate Taxes Multinationals UK

Autumn Statement 2014

Yesterday, the Chancellor of the Exchequer delivered the UK 2014 Autumn Statement. Below we summarise some of the main announcements: Taxation of multi-nationals - Diverted profits tax (aka the "Google tax")...more

12/10/2014 - Corporate Taxes Tax Reform UK

International Tax News - December 2013

CAYMAN ISLANDS AND US SIGN FATCA AGREEMENT - The United States and the Cayman Islands have signed a so-called Model 1 intergovernmental agreement. The IGA is the first step in bring the Cayman fund industry...more

12/12/2013 - Advance Pricing Agreements Advance Pricing Arrangement Program Anti-Avoidance FATCA Intergovernmental Agreements IRS Mutual Agreement Procedure Transfer Pricing UK VAT

International Tax News - October 2013

COLOMBIA ISSUES TAX HAVENS LIST: 4 THINGS TO NOTE FOR THOSE DOING BUSINESS IN COLOMBIA - Colombia has issued its list of tax havens – an act that will negatively impact the tax effects of doing business in Colombia...more

10/31/2013 - Australia Carbon Taxes Foreign Currency GAAR India International Tax Issues Tax Haven The Patent Box UK

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