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Capital Gains United Kingdom

Goodwin

A Token of Appreciation: Cryptoassets and Employee Incentives - a UK Tax Primer

Goodwin on

Businesses in the blockchain and cryptoasset space are increasingly looking to utilise digital currency and other cryptoassets as an alternative to or alongside other, more traditional employee incentive arrangements, such as...more

Cadwalader, Wickersham & Taft LLP

An option to dispose of property does not necessarily give rise to a taxable disposal

In the appeal case of Krishnamohan v HMRC [2024] UKFTT 346, the UK’s First-Tier Tribunal (“FTT”) determined that an agreement titled “Option Agreement” that was entered into to dispose of certain properties, does not, for...more

McDermott Will & Emery

UK Labour Party's Statement on Non-Dom Tax Reforms

McDermott Will & Emery on

Following the UK Government’s 6 March announcement of tax reforms for the current “non-dom” tax regimes, the opposition Labour party has begun to outline how its plans would differ if they win the next UK general election. In...more

Proskauer - Tax Talks

Change to non-domicile tax regime forms part of UK Spring Budget 2024

Proskauer - Tax Talks on

As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (the...more

Proskauer Rose LLP

UK Tax Round Up - December 2023

Proskauer Rose LLP on

Welcome to December’s edition of our UK Tax Round Up. This month has seen two interesting decisions on the connections needed for amounts to be taxed as employment income, the latest instalment in the BlueCrest partner...more

Skadden, Arps, Slate, Meagher & Flom LLP

Activists Assemble: Recent Trends in Activist Campaigns Targeting UK Investment Trusts

The United Kingdom has long been a target destination for activist investors. It is the venue for nearly half of all of recent activist campaigns in Europe. In previous articles, we have discussed how informed boards should...more

Dechert LLP

New Luxembourg-UK Double Tax Treaty Will Introduce Key Changes Including Access to Treaty Benefits for CIVs / Investment Funds

Dechert LLP on

Following the Luxembourg parliament’s ratification of the new Luxembourg-UK double tax treaty (“DTT”) on 19 July 2023, the new DTT should take effect in 2024. The UK ratified the new DTT on 7 June 2022....more

Cadwalader, Wickersham & Taft LLP

Court of Justice Rules on UK Group Asset Transfer Rules

The UK tax legislation imposes an “exit tax charge” on the unrealised capital gains of a company which migrates from the UK. The exit of a taxpayer (or their assets) is generally the last point in which a taxing jurisdiction...more

Hogan Lovells

Carried interest: legal challenge to the UK tax treatment

Hogan Lovells on

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

Proskauer Rose LLP

UK Tax Round Up - May 2023

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Welcome to May’s edition of our UK Tax Round. This month has been relatively quiet but there were a couple of cases that affect transactions that we see in practice, including an interesting update on what could constitute a...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2023 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more

BCLP

Delay to Luxembourg-UK treaty changes - impact on UK real estate

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Unexpectedly, it is likely the changes to the Luxembourg-UK double tax treaty will not be effective until 2024 at the earliest. Where that is the case, some Luxembourg investors in UK property rich entities will have another...more

Proskauer Rose LLP

UK Tax Round Up - November 2022

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Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more

A&O Shearman

The new Luxembourg/United-Kingdom tax treaty has been signed.

A&O Shearman on

More than four years after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail. As expected, the new...more

Goodwin

The UK and Luxembourg Signed A New Double Tax Treaty

Goodwin on

On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. An additional protocol will replace the tax treaty signed in...more

BCLP

Tax changes to Luxembourg structures investing in UK real estate

BCLP on

The UK and Luxembourg have renegotiated their double tax treaty. The new treaty has been published, but is not yet in force. Significant changes have been made to the capital gains tax article amongst other provisions....more

Pillsbury Winthrop Shaw Pittman LLP

Establishing and Managing a Business in the UK 2022

Overseas investors are welcome in the UK. Save as set out below, there are no specific laws prohibiting foreign investment in the UK nor are there any business requirements for UK participation in the ownership or management...more

BCLP

Impact of UK Autumn Budget on real estate sector

BCLP on

It was a relatively light Budget for the real estate sector. Highlights included the long-awaited announcement of the rate of the residential property developer tax and some reform of business rates....more

Katten Muchin Rosenman LLP

Putting the ‘S' in OTS: UK Capital Gains Tax

In the last six months, the Office of Tax Simplification (OTS) has published two reports evaluating the effectiveness of the capital gains taxation system in the UK. These reports suggest amendments to the existing system....more

Vinson & Elkins LLP

UK Budget 2021: Tax Perspectives

Vinson & Elkins LLP on

On 3 March 2021, UK’s Chancellor Rishi Sunak announced the 2021 Budget, outlining the state of the economy and the government’s fiscal plans for the near to medium term. As expected, the chancellor’s speech focused on changes...more

Cadwalader, Wickersham & Taft LLP

UK Asset Holding Companies: What Does the Future Hold?

The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021. The objectives of the UK Government in the consultation have been to improve...more

Proskauer Rose LLP

UK Tax Round Up - January 2021

Proskauer Rose LLP on

UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more

Proskauer - Tax Talks

New OTS report recommends changes to UK’s capital gains tax regime

Proskauer - Tax Talks on

The Office of Tax Simplification (OTS) has published its first report following its review of certain aspects of the UK’s capital gains tax regime requested by the Chancellor in July this year with the specific purpose of...more

Katten Muchin Rosenman LLP

The Principal Private Residence Relief – Practical Problems During the COVID-19 Pandemic

Principal private residence relief (PPR) provides an individual disposing of their main or principal place of residence (their ‘dwelling-house’ — such term is not defined in the legislation, but generally includes buildings...more

Katten Muchin Rosenman LLP

UK Entrepreneurs' Relief Takes a Hit Following the March Budget

Entrepreneurs' relief (ER) provides for a lower rate of capital gains tax (10 percent) to be paid when disposing of all, or part, of a business, or shares or securities in a personal company, or shares from an EMI scheme,...more

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