In light of Brexit, the U.K. government has made the unexpected announcement that it will limit DAC6 (Directive 2018/822) reporting in the U.K. to matters involving arrangements with the effect of concealing the ultimate...more
- As of January 1, 2021, Luxembourg is set to disallow otherwise tax deductible interest or royalty expense for payments made to entities resident in EU blacklisted jurisdictions that qualify as a beneficial owner “related”...more
The ongoing COVID-19 health crisis has resulted in significant changes to working practices in the United Kingdom (U.K.) and elsewhere. With a number of territories moving into aggressive suppression phases to halt the...more
3/27/2020
/ Board of Directors ,
Coronavirus/COVID-19 ,
Infectious Diseases ,
International Tax Issues ,
Investment Management ,
Principal Place of Business ,
Public Health ,
Remote Working ,
Tax Planning ,
Travel Restrictions ,
Traveling Employee ,
UK
The Upper Tribunal (UT) has found that amounts paid by Hargreaves Lansdown (HL) (an investment platform service provider) to its customers, which represented rebates received from investment fund managers, were “annual...more
8/30/2019
/ Fund Managers ,
Income Taxes ,
Investment Funds ,
Investment Management ,
Investors ,
Management Fees ,
Rebates ,
Tax Exemptions ,
Tax Liability ,
UK ,
Withholding Tax
We set out below a recap of some of the key European and international tax developments to note at the start of 2019. This alert provides a brief summary of the following...more
1/18/2019
/ Anti Tax Avoidance Directive (ATAD) ,
Anti-Avoidance ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Disclosure Requirements ,
Double Taxation ,
EBITDA ,
EU ,
European Commission ,
International Tax Issues ,
Member State ,
NAFTA ,
OECD ,
Tax Reform ,
UK ,
UK Brexit
On 23 May 2018, the United Kingdom ratified the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, otherwise known as the ‘Multilateral Instrument’ (“MLI”). The...more
• Individuals that are UK tax resident and non-UK domiciled have the ability until 5 April 2019 to cleanse their mixed overseas funds and accounts.
• Affected individuals should act now to review their position and assess...more
3/30/2018
/ Accountants ,
Capital Gains ,
Domicile ,
Filing Deadlines ,
Foreign Bank Accounts ,
Foreign Tax ,
Fund Managers ,
Income Taxes ,
International Finance ,
Notification Requirements ,
Recordkeeping Requirements ,
Remittance Transfer Rule ,
UK
The Criminal Finance Act 2017 received Royal Assent on April 27, 2017, making its way onto the statute book before the halting of Parliamentary business ahead of this year’s general election. As well as giving enforcement...more
On Wednesday 23 November 2016, Philip Hammond delivered the U.K. Autumn Statement, which included a number of announcements of relevance to the financial services industry. While relatively few new tax measures were...more
The result of the UK’s referendum of 23 June 2016 was announced today as a victory for ‘Brexit’ - in other words, for the UK to exit the European Union. This decision is expected to have significant ramifications for the...more
6/27/2016
/ Alternative Investment Funds ,
Corporate Taxes ,
EU ,
Income Taxes ,
Member State ,
Multinationals ,
Stamp Taxes ,
Subsidiaries ,
Tax Avoidance ,
UK ,
UK Brexit ,
Value-Added Tax (VAT) ,
Withholding Tax
The qualifying private placement exemption, which became available on 1 January 2016, makes interest on privately placed notes and/or bilateral loans exempt from United Kingdom withholding tax in certain circumstances where...more
Executive Summary -
Her Majesty’s Revenue & Customs (HMRC) has now published its response to the U.K. Supreme Court’s recent judgment in Anson v HMRC. The response confirms that HMRC will continue its existing practice...more
1. Executive Summary -
The U.K. corporate tax landscape has been undergoing reform for a number of years. A significant part of the changes involves the ongoing modernization of the U.K.’s complex tax regime for...more