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The UK’s New Asset Holding Company Tax Regime – Might You Be Enticed to Be Offshore No More?

Introduction The UK’s new Qualifying Asset Holding Company Regime (the “QAHC Regime”) comes into effect on 1 April 2022. The main objective of the regime is to make the UK a more desirable jurisdiction from which funds (which...more

Update: Taking Off The Blinkers: The Delayed UK “Off-Payroll Working” Reforms Are (Nearly) Here

One year ago, the UK Government announced that the changes to the off-payroll working rules (also known as IR35) (the “Rules”) would enter into force on 6 April 2021 rather than 6 April 2020, due to the impact of the COVID-19...more

New Year, New Rules: UK Reconsiders DAC6 Reporting Obligations

On 31 December 2020, HMRC unexpectedly announced that the UK will repeal the implementation of the EU Directive on administrative cooperation (“DAC6”).Instead, the UK will introduce its own mandatory disclosure rules (“MDR”)...more

Coronavirus (COVID-19): “Future Fund” Launched To Support UK High Growth Companies

With many early-stage, high growth businesses facing economic upheaval and pressure on their cash flow as a result of COVID-19, the Chancellor of the Exchequer has announced a £1.25 billion support package to help innovative...more

Impact Of COVID-19 On UK Corporate Tax Residency: OECD And HMRC Guidance Issued

The COVID-19 pandemic has resulted in significant disruption to international travel and business arrangements. Enforced travel restrictions have left many people, including company directors and employees, stranded outside...more

COVID-19 Update – What Do The Latest Proposals Mean For UK Employers?

On 23 March 2020, Boris Johnson announced that the UK would effectively be going into “lockdown” for a period of at least three weeks, in order to tackle the spread of coronavirus. This means closing all non-essential shops...more

IR35 Update – Employment Language

In the UK Government’s latest Budget, delivered on 11 March 2020, it was announced that the changes to the off-payroll working rules (also known as IR35) previously announced at Budget 2018 would apply to the private sector...more

Cayman Islands Added To European Union Tax Blacklist

The Council of the European Union confirmed on Tuesday, 18 February 2020 that the Cayman Islands, a British overseas territory, has been added to the European Union’s ‘blacklist’ of non-cooperative jurisdictions for tax...more

2/21/2020  /  BEPS , Cayman Islands , EU , Member State

The UK’s Last Budget Before Brexit – Tech, Tax and Temerity

A digital services tax for “tech giants”, additional conditions for Entrepreneurs’ Relief, amendments to the loss relief rules, and a host of tax-avoidance measures: we outline the key tax proposals from the Autumn Budget...more

State Aid Approval Renewed for UK EMI Schemes

The European Commission has renewed state aid approval for the UK Enterprise Management Incentive (EMI) regime. Following an unexpected bulletin from HM Revenue & Customs (HMRC) on 4 April 2018, announcing that state aid...more

5/31/2018  /  EU , European Commission , HMRC , State Aid , UK

EU Digital Market VAT Reform

Since 2015, the European Union has been gradually implementing a series of reforms designed to create a Digital Single Market across the EU. In setting its reform agenda, the European Commission looked beyond areas...more

The UK Double Tax Treaty Passport Scheme – Changes for the UK Loan Market

The UK Double Tax Treaty Passport (“DTTP”) scheme has recently been extended by HM Revenue & Customs (“HMRC”) to allow both non-corporate borrowers and lenders to enjoy the benefits of the scheme. The aim of the amendments is...more

Brexit: Tax Implications

The majority has spoken: on Friday 24 June, it was announced that the UK had voted to leave the European Union (the “EU”). The full implications of this decision are largely unknown, given that the UK is navigating...more

European M+A News, Winter 2016

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

New UK Withholding Tax Exemption Set to Boost the UK Private Placement Market

On 4 December, George Osborne in his Autumn Statement, announced a new UK withholding tax exemption for interest payments on UK private placements. The announcement was followed by draft legislative clauses with the Finance...more

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