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The Scambler Case: Tax Law in Plain English?

A recent decision of the Upper Tribunal (Tax and Chancery Chamber) (UT) in Scambler and another v HMRC [2017] UKUT 1 (TCC) considers the question of when it is appropriate to look back to earlier versions of tax legislation...more

Key Money and Exclusivity Arrangements—What You Need to Know

Key Money Overview - The payment of key money (KM) by hotel operating companies is an increasingly regular aspect of securing hotel management agreements, particularly in the luxury hotel sector. In the typical...more

UK Tax: When Partnership Is Not Partnership

The recent decision of the First Tier Tribunal (FTT) in the unusual case of R. Ashton v HMRC [2016] UKFTT 727 serves as a useful reminder to taxpayers of two issues: (1) the potential for confusion when distinguishing between...more

1/30/2017  /  Corporate Taxes , Partnerships , UK

Dollar Financial UK Ltd v HMRC: When Must a Financial Intermediary Charge VAT?

Executive Summary - The decision in Dollar Financial UK Ltd v HMRC [2016] UKFTT 598 will likely be of interest to a range of participants in the lending market, and the financial services sector more generally, because...more

Withholding Tax Contrary to EU Law: The Brisal Case

On 13 July, the Court of Justice of the European Union (CJEU) released its decision in the Brisal case (C-18/15). The Brisal case has potentially far reaching implications for European Union (EU) businesses that either...more

What Does Brexit Mean for UK Tax?

Once the formal procedure under Article 50 of the Lisbon Treaty is initiated by the United Kingdom, the government will negotiate the terms of its exit from the European Union. Whilst we must accept that this is a period of...more

Summer Budget 2015––Carried Interest: Abolition of Base Cost Shift

On July 8, the Right Honourable George Osborne MP, Chancellor of the Exchequer, introduced measures in his Summer Budget to abolish what is commonly known as the “base cost shift” as applied to sums received by individuals...more

Corporate & Financial Weekly Digest - Volume X, Issue 27

In this issue: - Court of Appeals for Third Circuit Overturns District Court Ruling Regarding Exclusion of Shareholder Proposal From Proxy Statement - FINRA Updates Its Interpretation of the SEC's Financial...more

OECD Publishes Initial Recommendations on BEPS

On September 16, the Organisation of Economic Co-operation and Development (OECD) published a set of recommendations for a coordinated approach to fight tax avoidance by multinational enterprises under the Base Erosion and...more

Corporate and Financial Weekly Digest - Volume IX, Issue 38

In this issue: - SEC Releases Strategic Plan for 2014–2018 - House Passes Bill H.R. 5405 “Promoting Job Creation and Reducing Small Business Burdens Act” - FINRA Board Approves Several Rulemaking Items...more

OECD Publishes its Standards for the Automatic Exchange of Information

On July 21, the Organisation for Economic Co-operation and Development (OECD) published its Standard for Automatic Exchange of Financial Account Information in Tax Matters. The report contains the OECD’s model competent...more

Corporate and Financial Weekly Digest - Volume IX, Issue 35

In this issue: - SEC Decreases Registration Statement Filing Fees for Fiscal Year 2015 - SEC Adopts Regulation AB II - US Banking Regulators Propose Margin Requirements for Uncleared Swaps - CME...more

Taxation of Salaried Members: An Update for Asset Managers

Background - Last summer, HM Revenue & Customs (HMRC) published proposals for major changes to the UK's rules on the taxation of partnerships. The primary aim of the proposals was to counter arrangements which HMRC...more

3/12/2014  /  HMRC , Income Taxes , Partnerships , UK

Project Blue: A Stamp Duty Land Tax Case That Made Headlines

In July 2013, the Stamp Duty Land Tax (SDLT) case of Project Blue Ltd v. HM Revenue & Customs, concerning the high-profile development of Chelsea Barracks, was the first real test of the SDLT’s broad anti-avoidance rule...more

SDLT Schemes: The Good, The Bad and The Ugly

The Chancellor had previously warned that he would “not hesitate to move swiftly, without notice and retrospectively” to counter aggressive and widely marketed Stamp Duty Land Tax (SDLT) schemes. Last week, when announcing...more

3/27/2013  /  HMRC , Stamp Duty Land Tax

The European Financial Transaction Tax Proposal Returns

On 14 February 2013, the European Commission (the “Commission”) released draft text for a proposed financial transaction tax Directive (the “Draft Proposal”). If the text is implemented into law a financial transaction tax...more

2/15/2013  /  EU , Financial Transaction Tax
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