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Corporate Criminal Offence: Failure to Prevent Facilitation of Tax Evasion

The Criminal Finance Act 2017 received Royal Assent on April 27, 2017, making its way onto the statute book before the halting of Parliamentary business ahead of this year’s general election. As well as giving enforcement...more

Qualifying Private Placement Exemption

The qualifying private placement exemption, which became available on 1 January 2016, makes interest on privately placed notes and/or bilateral loans exempt from United Kingdom withholding tax in certain circumstances where...more

UK tax treatment of US LLCs: HMRC responds to the Supreme Court’s decision in Anson v HMRC

Executive Summary - Her Majesty’s Revenue & Customs (HMRC) has now published its response to the U.K. Supreme Court’s recent judgment in Anson v HMRC. The response confirms that HMRC will continue its existing practice...more

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