UK General Tax Developments -
Stamp Duty and COVID-19 -
Since the start of the first UK lockdown in March 2020, HMRC has been accepting that documents can be stamped electronically. HMRC has now confirmed that, where...more
UK Case Law Developments -
EIS relief not available for shares carrying preferential rights -
The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more
3/10/2021
/ Corporate Taxes ,
EU ,
European Commission ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
OECD ,
Private Equity ,
Tax Avoidance ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
UK Prime Minister’s statement on COVID-19 -
On 31 October, the Prime Minister announced a number of measures designed to slow down the spread of COVID-19 to last for four weeks from 4...more
11/9/2020
/ BEPS ,
Corporate Taxes ,
European Commission ,
Fund Managers ,
HMRC ,
Income Taxes ,
Insurance Industry ,
International Tax Issues ,
OECD ,
OTS ,
Pension Schemes ,
Tax Authority ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 developments -
Proposed deferral of DAC6 and DAC2 -
The European Commission has published a draft directive proposing a three month delay to the deadlines for certain information disclosures under the EU...more
6/3/2020
/ Coronavirus/COVID-19 ,
Corporate Taxes ,
EU ,
European Commission ,
HMRC ,
Income Taxes ,
Infectious Diseases ,
International Tax Issues ,
Personal Protective Equipment ,
Tax Deductions ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK Case Law Developments -
Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation -
In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more
10/31/2019
/ Arm's Length Principle ,
Corporate Taxes ,
EU ,
European Commission ,
GAAR ,
HM Treasury ,
HMRC ,
Income Taxes ,
International Tax Issues ,
OECD ,
Private Equity ,
Share Purchase Agreements ,
Tax Planning ,
Transfer Pricing ,
UK ,
Value-Added Tax (VAT)
UK Case Law Developments -
Damages on share sales same as on other sales -
In Oversea Chinese Banking Corporation Ltd v ING Bank NV, the Commercial Court has held that the measure of damages for breach of warranty in...more
5/2/2019
/ Acquisitions ,
Capital Gains ,
Controlled Foreign Corporations ,
EU ,
European Commission ,
HMRC ,
International Tax Issues ,
Mergers ,
Private Equity ,
Shareholders ,
State Aid ,
Stock Options ,
UK ,
Warranties
UK Case Law Developments -
Entrepreneurs' relief – voting rights not imputed for equitable reasons -
In George v HMRC, the First Tier Tribunal (FTT) decided that they could not apply the equitable principle that...more
10/8/2018
/ BEPS ,
Corporate Taxes ,
EU ,
European Commission ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Ireland ,
Share Purchase Agreements ,
Tax Planning ,
Tax Tribunal ,
UK ,
Value-Added Tax (VAT)
General UK Tax Developments -
Enterprise management incentive (EMI) options State Aid approval -
We referred in the April UK Tax Round Up to the expiry of the EU's State Aid approval for EMI options. Fortunately, this...more
5/31/2018
/ Acquisitions ,
Anti-Avoidance ,
BEPS ,
Capital Losses ,
Corporate Taxes ,
EU ,
European Commission ,
Foreign Subsidiaries ,
HMRC ,
International Tax Issues ,
Mergers ,
UK ,
Value-Added Tax (VAT)
Welcome to the March edition of the Proskauer UK Tax Round Up. As promised, the Spring Statement from the Chancellor focused on the economy and public finances without any major tax announcements. However, a few interesting...more
4/5/2018
/ Anti-Avoidance ,
Capital Gains ,
Controlling Person ,
Corporate Taxes ,
Court of Justice of the European Union (CJEU) ,
Cross-Border ,
Entrepreneurs ,
EU ,
European Commission ,
Federal Budget ,
Foreign Investment ,
GAAR ,
HMRC ,
International Tax Issues ,
Investment Management ,
Limited Partnerships ,
Remuneration ,
Tax Credits ,
Tax Rates ,
UK
The impact of discounts on consideration for VAT purposes (Finanzamt Bingen-Alzey v Boehringer Ingelheim Pharma GmbH & Co. KG) -
The ECJ has confirmed that consideration for VAT purposes should be reduced by any discount...more
1/29/2018
/ Corporate Bonds ,
Corporate Taxes ,
EU ,
European Commission ,
European Court of Justice (ECJ) ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Share Purchase Agreements ,
Tax Planning ,
Tax Tribunal ,
Tax Warrants ,
UK ,
Value-Added Tax (VAT)
UK Tax News and Developments -
The OTS publishes its report "Value added tax: routes to simplification" -
On 7 November, the Office of Tax Simplification (OTS) published its first report on VAT, which included a range...more
11/30/2017
/ CFC ,
Corporate Taxes ,
Court of Justice of the European Union (CJEU) ,
Diverted Profits Tax ,
Draft Guidance ,
EU ,
European Commission ,
HMRC ,
Income Taxes ,
International Tax Issues ,
National Insurance Contributions ,
OTS ,
Remuneration ,
Restitution ,
Self-Employment Tax ,
Tax Reform ,
Threshold Requirements ,
UK ,
Value-Added Tax (VAT)