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
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
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
UK securitisations using an EU-based securitisation vehicle may get a VAT benefit post-Brexit transition. Currently, VAT on securitisation costs is likely irrecoverable for UK originators. ...more
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
2/6/2020
/ Anti-Avoidance ,
Digital Services Tax ,
Disclosure ,
Disclosure Requirements ,
EU ,
EU Directive ,
Financial Transactions ,
International Tax Issues ,
OECD ,
Regulatory Requirements ,
State Aid ,
Tax Avoidance ,
Tax Planning ,
Tax Reform ,
Transfer Pricing ,
Transparency
It’s been a busy month in the world of tax for tech companies. France and the UK are introducing digital services taxes, and serious work is underway at the OECD that may result in a shake-up of the international tax system...more
Debt instruments are amended for a range of commercial reasons. It may be to replace references to LIBOR, to change bond restrictive covenants under a consent solicitation process or as part of an 'amend and extend' exercise...more
Those of us who regularly review debt facilities have probably noticed that the prospective (earliest) application date for FATCA withholding on "gross proceeds” from sales or other dispositions and "foreign passthru...more