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

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

UK Stamp Taxes – Removal of 1.5% “Brexit” charge – in the nick of time?

New draft UK legislation has been published today 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)...more

9/15/2023  /  HMRC , Stamp Taxes , UK

Carried interest: legal challenge to the UK tax treatment

Recent publicity around the UK taxation of carried interest may, in due course, make it more likely that a UK government would look again at the tax rules around carried interest. ...more

How the UK Trust Registration Service applies to trusts of real estate and changes for unit trusts

Trustees which are UK resident, have UK assets or income which trigger a UK tax liability or directly acquire UK land on or after 6 October 2020 will generally have to register the trust with HMRC's Trust Registration Service...more

Potential additional hurdle to clear if interest on intra-group debt is to be tax deductible in the UK

In applying the UK’s transfer pricing rules, tax advisers have to think beyond the amount of the debt and the interest rate to get comfortable that an intra-group loan is going to be tax deductible. Following a recent case,...more

Applying an arm’s length comparator to intra-group debt: the role of third-party covenants

When applying the UK’s transfer pricing rules to compare an intra-group loan to the hypothetical arm’s length transaction that an independent third-party lender would have agreed to, there is no scope to read in covenants...more

Anti-money laundering: which trusts in the UK real estate sector must register by 1 September 2022?

Trustees holding UK real estate must generally register the trust with HMRC following the extension of the Trust Registration Service. The TRS was launched in 2017 by the UK government as part of its implementation of the...more

Important changes to DAC6 regime in the UK: impact on bank lending transactions

The UK has made important changes to its implementation of the EU Mandatory Tax Disclosure Rules known as DAC6. The changes, which significantly reduce the scope of the rules in the UK ...more

Important changes to DAC6 regime in the UK

The UK has made important changes to its implementation of the EU Mandatory Tax Disclosure Rules known as DAC6. The changes, which significantly reduce the scope of the rules in the UK, are largely good news for UK taxpayers...more

Tech Tax – Looking Forward to 2020

Following-up from our previous blogs on Tech Tax, we thought it would be useful to take a whirlwind tour of what to expect in tax and transfer pricing related topics in 2020. But for those that are curious, why are such...more

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