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
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
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
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
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
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