Peita Menon

Peita Menon

White & Case LLP

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UK Budget 2016 – Overview

The Chancellor has presented a packed March Budget bursting at its seams with measures impacting businesses and individuals alike... ..The first reference to tax in his statement was to "tax avoidance" and that tells...more

3/17/2016 - Anti-Avoidance Budgets Corporate Taxes EBITDA Property Tax Tax Rates UK

Private Placement Exemption: New UK withholding tax exemption for private placements

The new rules at a glance - Broadly, from 1 January 2016, there will be no UK withholding tax on interest payments on a loan/security which meets all of the requirements below: - not listed on a recognised stock...more

3/8/2016 - International Tax Issues Loans Private Placements Securities Tax Exemptions UK Withholding Tax

New year, new exemption: The UK withholding tax exemption for privately placed debt

Just over a year since the Chancellor of the UK Exchequer George Osborne announced in his Autumn Statement 2014 the introduction of a UK withholding tax exemption for interest paid under private placements (a form of unlisted...more

1/6/2016 - Creditors Debt Foreign Investment HMRC Private Placements UK Withholding Tax

Finance Bill 2016: asset manager remuneration reform

Following years of targeting the banking industry in order to increase tax revenue, the UK Government has started to focus its attention more keenly on the remuneration of asset managers (particularly carried interest...more

12/13/2015 - Asset Management Banks Business Taxes Capital Gains Investment Funds Remuneration UK

UK Autumn Statement 2015

This has been a rather underwhelming Autumn Statement by the Chancellor from a tax perspective as it is lighter in tax content than usual. Unlike in recent years, non-domiciled taxation did not feature prominently in this...more

11/30/2015 - Business Taxes Debt Executive Compensation GAAR Stamp Duty Land Tax Tax Reform UK

UK Summer Budget 2015: Osborne's 'Big Summer Budget' – the key measures impacting business

The first fully Conservative Budget for 18 years, following the end of the Coalition as a result of the May general election, was anticipated to be a 'Big Budget' but in truth it was a mixed bag: the game changers are the...more

7/14/2015 - Anti-Avoidance Banks Carried Interest Carried Interest Tax Rates Controlled Foreign Corporations Corporate Taxes Derivatives Federal Budget HMRC Inheritance Tax Investment Funds Levy Resident Non-Domiciled (RND) Tax Reform UK

Private placements: a new UK withholding tax exemption

The Finance (No.2) Bill 2015 contains provisions for an exemption from the obligation to deduct UK income tax from yearly interest paid on “qualifying private placements”. This measure was first announced on 3 December...more

3/31/2015 - Economic Action Plan Income Taxes Interest Income Investment Funds Private Placements Tax Exemptions UK Withholding Tax

Ship on course but choppy waters abound! UK Budget 2015: 10 key measures impacting business

Before the Budget was announced, there was natural apprehension that, given the impending general election, the Chancellor would pander to the electorate and sail off course from this Government’s carefully navigated path...more

3/23/2015 - Anti-Avoidance Banks Capital Gains Corporate Taxes Derivatives Diverted Profits Tax Entrepreneurs Federal Budget Investment Management Loans Oil & Gas Private Placements Residential Real Estate Market Tax Credits Tax Exemptions Tax Rates UK

A new UK withholding tax exemption for privately placed debt

The Chancellor of the UK Exchequer, George Osborne, announced in the 2014 Autumn Statement on Wednesday a new targeted exemption from UK withholding tax for interest on qualifying privately placed debt. The exemption is a...more

12/8/2014 - Corporate Taxes Tax Exemptions Tax Reform UK

Stamp duty and SDRT exemption: recognised growth markets

As first announced in Budget Speech 2013, the Finance Bill 2014 abolishes, with effect from 28 April 2014, stamp duty and stamp duty reserve tax (SDRT) on transactions in shares and securities admitted to trading on a...more

6/2/2014 - Stamp Duty Land Tax Stamp Taxes UK

Fixtures Allowances in Commercial Property Transactions: Pooling and Fixed Value Requirements

New rules concerning capital allowances on the disposal of fixtures (first announced in 2011) are now in full force. The changes, which are procedural and impose additional formalities, are: - Mandatory pooling (which...more

5/27/2014 - Asset Valuations Commercial Property Owners Fixtures Forced Pooling IRS Withholding Allowances

Global Tax Report - September 2013: Intellectual Property Tax Planning

In This Issue: - United States: Benefits of Intangible Property Migrations - United Kingdom: Innovation: The Name of the Game - Germany: OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) Within the...more

9/16/2013 - Erosion EU Innovation Intangible Property Tax Planning UK

A nuisance called FATCA – Does the UK/US IGA make it bearable?

The introduction by the US of the Foreign Account Tax Compliance Act 2010 (FATCA) set the proverbial cat amongst the pigeons in the international loan financing markets by requiring foreign and domestic borrowers, lenders and...more

4/15/2013 - Borrowers FATCA FFI Intergovernmental Agreements IRS Lenders

India Budget 2013: Key Changes Affecting International Investors

On February 28, 2013, India’s Finance Minister presented the country’s budget for the fiscal year beginning April 1, 2013 (Budget). The Budget includes several proposals that affect international investors investing in India,...more

3/15/2013 - Business Taxes Foreign Investment GAAR India Royalties Tax-Residency Certificate

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