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Corporate Governance HMRC

Latham & Watkins LLP

Recent Developments for UK PLCs - September 2024

Latham & Watkins LLP on

On 13 August 2024, the Financial Reporting Council (FRC), as part of a cross-regulatory group comprising the FCA, Companies House, HMRC and Charity Commission for England and Wales, published a discussion paper on the future...more

Proskauer - Tax Talks

UK Supreme Court confirms no deduction for expenses related to share and asset sale

Proskauer - Tax Talks on

On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of...more

Proskauer Rose LLP

UK Tax Round Up - March 2024

Proskauer Rose LLP on

Welcome to March’s edition of our UK Tax Round Up. This month has seen a number of interesting cases covering a range of issues, from the deductibility of costs against employment income to the place of effective management...more

J.S. Held

The Diverted Profits Tax & Royalty Withholding Tax: Impacts on Intellectual Property Licenses and Transactions

J.S. Held on

The Diverted Profits Tax (DPT) has been a significant area of focus for taxpayers and tax authorities in the UK and Australia. The tax targets specific situations in which taxable profits are alleged to have been “diverted”...more

White & Case LLP

The HMRC Restructuring Plan Challenges: Lessons Learned from GAS, Nasmyth and Prezzo

White & Case LLP on

Earlier this year, the English Court refused to sanction two Part 26A restructuring plans ("RPs") which sought to bind HMRC, the UK tax authority, into restructurings via "cross-class cram down". (See "Restructuring Plans...more

Hogan Lovells

UK government plans to introduce a re-domiciliation regime

Hogan Lovells on

On 27 October 2021, HM Treasury, BEIS and HMRC published a consultation paper seeking views on proposals for a UK re-domiciliation regime under which foreign-incorporated companies could change their place of incorporation to...more

Proskauer Rose LLP

UK Tax Round Up - June 2019

Proskauer Rose LLP on

Guernsey SPV not resident in the UK - In Development Securities plc and others v HMRC, the Upper Tribunal (UT) has overturned the prior discussion of the First-tier Tribunal (FTT) in favour of the taxpayer in an important...more

Proskauer Rose LLP

UK Tax Round Up - July 2017

Proskauer Rose LLP on

UK Tax News and Developments - Conservative legislative agenda set out in Queen's Speech - Following the UK general election on 8 June 2017, at which the Conservative party won the largest number of seats but lost its...more

Dechert LLP

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Dechert LLP on

Tax: HMRC Publishes Filing Dates for New AIFM Mechanism for Partnership Deferred Remuneration Arrangements - The Finance Act 2014 introduced a provision intended to help partnerships (including LLPs) that are AIFM...more

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