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Corporate Taxes United Kingdom

Cadwalader, Wickersham & Taft LLP

Recognising “Imported Losses” Under the UK’s Loan Relationship Rules

The United Kingdom (“UK”) has specific corporate tax rules on the taxation of loan relationships (parts 5 and 6 of the Corporation Tax Act 2009 (the “Loan Relationships Regime”)). The Loan Relationships Regime contains rules...more

Walkers

15% Global Minimum Tax Rate: Draft Legislation lodged in Jersey

Walkers on

Following Jersey's intention to implement the OECD proposals for a 15% global minimum tax rate (known as "Pillar 2") in May 2024, draft legislation has now been lodged introducing a new standalone Multinational Corporate...more

BCLP

A Capital Blow for Deducting Management Expenses

BCLP on

The Supreme Court confirmed in Centrica Overseas Holdings Ltd v HMRC that the tests for trading and management expenses of a capital nature are the same. The decision also confirms that once a company has decided in principle...more

Latham & Watkins LLP

Charging Ahead: Grappling With the Characterisation of Fixed and Floating Charges

Latham & Watkins LLP on

The characterisation of fixed and floating charges remains a complex area, not least with respect to new intangible asset types. The key distinction between a fixed and a floating charge is well established as a matter of...more

Proskauer - Tax Talks

UK Supreme Court confirms no deduction for expenses related to share and asset sale

Proskauer - Tax Talks on

On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of...more

McDermott Will & Emery

Protecting Employees’ Tax Position After a Spin-off

McDermott Will & Emery on

Spin-offs have become increasingly popular with innovative companies as a method of unlocking shareholder value, but the transaction is not always tax-free, particularly for international employees holding equity awards or...more

Pillsbury Winthrop Shaw Pittman LLP

Landslide Election Victory for UK Labour Party Marks Seismic Shift in UK’s Political Terrain

The Labour Party outlines areas of potential focus for the next UK Parliament. The UK Labour Party won a sizeable parliament majority in the UK general election on July 4, 2024, as it took 411 of the 650 seats in the UK...more

Cadwalader, Wickersham & Taft LLP

Ascertaining the Purpose of a Loan Relationship

The UK has specific corporate tax rules on the taxation of loan relationships (parts 5 and 6 of the Corporation Tax Act 2009 (the “Loan Relationship Regime”). The Loan Relationship Regime contains wide-ranging anti-avoidance...more

Mayer Brown

UK Election Bulletin: What would a Labour government mean for businesses?

Mayer Brown on

Overview - On 22 May 2024, UK Prime Minister Rishi Sunak announced that he had requested permission from King Charles III to dissolve parliament and call a general election. The election will take place on 4 July 2024....more

Wilson Sonsini Goodrich & Rosati

FAQs: UK Employee Equity Incentive Annual Reporting Deadline Approaching

2023/2024 Annual Returns Must Be Filed by July 6, 2024 - Companies operating employee equity incentive arrangements in the United Kingdom, including companies incorporated or registered outside of the United Kingdom, are...more

Walkers

Guernsey and Jersey re-affirm commitment to OECD Pillar Two implementation

Walkers on

The Crown Dependencies have re-affirmed their commitment to international tax standards and the continued value of inter-island cooperation in areas of mutual interest in international tax policy. Ministers from...more

Latham & Watkins LLP

Lexology In-Depth - Acquisition And Leveraged Finance

Latham & Watkins LLP on

It was a muted start to the year for the acquisition and leveraged finance market due to a challenging macroeconomic climate. Interest rate hikes at one of the fastest paces on record, surging inflation (particularly in...more

Wilson Sonsini Goodrich & Rosati

Changes to Notification Requirements for EMI Options Granted On or After April 6

Companies granting enterprise management incentive (EMI) options to their UK tax resident employees are reminded they must notify HM Revenue & Customs (HMRC) of the awards. Failure to do so means that the option is not EMI...more

Walkers

Why Jersey and Guernsey companies are a great choice for UK REITs

Walkers on

What is a UK REIT? A Real Estate Investment Trust (REIT), despite the name, is a company (or group of companies) carrying on a property rental and investment business which, if it meets certain conditions, can elect to...more

Latham & Watkins LLP

Restructuring Plans and Tax Liabilities A More Assertive HMRC

Latham & Watkins LLP on

Companies must approach HMRC with suitable care when proposing a restructuring plan, mindful of lessons learned from recent case law. Ever since unpaid taxes due to HMRC were “crammed down” pursuant to a restructuring plan...more

Morgan Lewis

UK Sovereign Immunity from Direct Taxation

Morgan Lewis on

Sovereign immunity is a principle of public international law whereby one sovereign state should not seek to apply its law to another sovereign state. Alongside the jurisdictional immunity foreign sovereigns enjoy in the...more

BCLP

Spring Budget 2024 - Will We See Material Reform?

BCLP on

Budgets are normally stories of two halves. The first half contains the headline-grabbing tax policy reforms that can be encapsulated in a snappy soundbite in the Budget speech, such as “Chancellor scraps the non-dom regime”....more

J.S. Held

The Diverted Profits Tax & Royalty Withholding Tax: Impacts on Intellectual Property Licenses and Transactions

J.S. Held on

The Diverted Profits Tax (DPT) has been a significant area of focus for taxpayers and tax authorities in the UK and Australia. The tax targets specific situations in which taxable profits are alleged to have been “diverted”...more

Proskauer Rose LLP

UK Tax Round Up - January 2024

Proskauer Rose LLP on

Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...more

International Lawyers Network

Buying and Selling Real Estate in England and Wales (Update)

KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER BRITISH LAW - 1. Introduction - Historically, there has been significant investment by overseas individuals and corporations in real estate in England and Wales and in...more

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on

In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

A&O Shearman

What does Pillar Two mean for structured finance?

A&O Shearman on

Born of the OECD’s base erosion and profit shifting (BEPS) project, the Pillar Two rules introduce a global minimum corporate tax rate of 15% on multinationals of a certain size. The reforms reflect the outcome of an...more

Hogan Lovells

Third time lucky? 1.5% UK stamp tax vs “Brexit 3.0” - update

Hogan Lovells on

Draft UK legislation was previously published proposing to remove the 1.5% stamp tax charge on issues, and certain transfers, of securities to depositary receipt systems and clearance services (or their nominees) currently...more

BCLP

Impact of the UK’s Autumn Statement 2023 on Real Estate

BCLP on

In contrast to recent years, when there has been plenty for real estate tax lawyers to feast on, this Autumn Statement was fairly quiet.  Full expensing - After a prolonged period of time-limited, enhanced reliefs,...more

Cadwalader, Wickersham & Taft LLP

Hargreaves Property: What Does the Latest Decision Mean for UK Withholding Tax?

In many respects, the Upper Tribunal’s decision in Hargreaves Property  will not have surprised tax practitioners as the decision reaffirms best practice considerations around a number of fundamental concepts in relation to...more

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