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Double Taxation United Kingdom

Cadwalader, Wickersham & Taft LLP

GE Financial Investments: What Determines Residency?

Background - In GE Financial Investments Limited the Court of Appeal (“CoA”) overturned the Upper Tribunal’s (“UT”) decision and held that double taxation relief was not available under the UK-US double tax treaty (the...more

Holland & Knight LLP

Consejo de Estado de Colombia: CDI con Reino Unido no activó cláusula de nación más favorecida

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El CDI con Reino Unido no activó cláusula de nación más favorecida de los CDI con España, Suiza y Chile para servicios técnicos, de asistencia técnica y consultoría En Sentencia con Radicado 25411 del 4 de abril de 2024,...more

Proskauer Rose LLP

UK Tax Round Up - December 2023

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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

Cadwalader, Wickersham & Taft LLP

Hargreaves Property: What Does the Latest Decision Mean for UK Withholding Tax?

In many respects, the Upper Tribunal’s decision in Hargreaves Property  will not have surprised tax practitioners as the decision reaffirms best practice considerations around a number of fundamental concepts in relation to...more

Cadwalader, Wickersham & Taft LLP

Pin-pointing Residence

The identification of where a company is resident is a critical element in accessing the benefits of a double tax treaty. GE Financial Investments Limited (“GEFI Limited”) was a UK incorporated and tax resident company...more

Hogan Lovells

New double tax treaty between Luxembourg and the UK

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On 19 July 2023, the new convention for the elimination of double taxation (the “New Convention”) between Luxembourg and the United Kingdom (the “Contracting States”) and its protocol were ratified by the Luxembourg Chamber...more

Proskauer Rose LLP

UK Tax Round Up - October 2022

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Welcome to the October edition of the UK Tax Round Up. October has been an extraordinary month in the UK, with political turbulence triggering reversals of many of the tax policies announced by the government at the end of...more

Proskauer Rose LLP

UK Tax Round Up - September 2022

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Welcome to September’s edition of the UK Tax Round Up. In addition to the headline-grabbing 2022 Growth Plan announced by the UK Chancellor, there have been a number of interesting cases this month including the First-tier...more

Cadwalader, Wickersham & Taft LLP

Burlington Loan Management DAC: Treaty Shopping Provisions Did Not Apply

The UK’s First-tier Tribunal recently held that the payment of interest received by Burlington Loan Management DAC (“BLM”) (an Irish tax resident company) was not to be denied the benefits of the relief afforded under the...more

A&O Shearman

Great Fund Insights: The new Luxembourg/United-Kingdom tax treaty has finally been signed!

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More than four yeas 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. ...more

Vinson & Elkins LLP

Revised UK-Luxembourg Double Tax Treaty May Have Impact on Structures for Investing in UK Real Estate

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A new version of the UK-Luxembourg double tax treaty has been published in which significant changes have been made to the capital gains tax article, amongst other provisions....more

Cadwalader, Wickersham & Taft LLP

Haworth: Residency Tie-Breaker Tests in a ‘Round the World’ Tax Scheme

The UK’s First-tier Tribunal recently considered the application of the “place of effective management” residency tie-breaker test found in double tax treaties in the recent case of Haworth and others v HMRC [2022] UKFTT 34...more

Faegre Drinker Biddle & Reath LLP

Luxembourg Again Extends Cross-Border COVID-19-Related Agreements with Belgium

As we have previously discussed, Luxembourg has developed solutions with its neighboring nations to ease the economic burden of the COVID-19 pandemic on workers. Specifically, Luxembourg authorities worked with their...more

Proskauer Rose LLP

UK Tax Round Up - June 2021

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UK Case Law Developments - Income tax consequences of pension-related payments in E.ON v HMRC - E.ON v HMRC concerned a large UK power and gas supplier, which paid certain lump sum payments, called “facilitation...more

Proskauer Rose LLP

UK Tax Round Up - May 2021

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UK General Tax Developments - Stamp Duty and COVID-19 - Since the start of the first UK lockdown in March 2020, HMRC has been accepting that documents can be stamped electronically. HMRC has now confirmed that, where...more

Freeman Law

International Tax Treaty: The United Kingdom

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Quick Summary. In the United Kingdom, Her Majesty’s Revenue and Customs (HMRC) is responsible for administering and collecting taxes in the UK. For 2019, HMRC collected $841.19 billion in tax revenue. But it took over 300...more

Holland & Knight LLP

DIAN emite interpretación de Convenios para Evitar la Doble Tributación suscritos por Colombia

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El 13 de diciembre de 2019 entró en vigor el Convenio para Evitar la Doble Tributación entre Colombia y el Reino Unido e Irlanda del Norte y su aplicación en materia de retenciones en la fuente será a partir del 1 de enero de...more

Akin Gump Strauss Hauer & Feld LLP

European Tax Update January 2019

We set out below a recap of some of the key European and international tax developments to note at the start of 2019. This alert provides a brief summary of the following...more

Akin Gump Strauss Hauer & Feld LLP

UK ratifies the OECD’s Multilateral Instrument – Practical Impact and Timing of Implementation

On 23 May 2018, the United Kingdom ratified the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, otherwise known as the ‘Multilateral Instrument’ (“MLI”). The...more

Dechert LLP

HMT Unveils Strategy for Future of UK's Asset Management Industry

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HM Treasury recently published its Investment Management Strategy II Report. Building on its 2013 strategy report ? which mainly focused on how to improve the UK as a fund domicile ? this report sets out the UK government’s...more

Proskauer Rose LLP

UK Tax Round Up - October 2017

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UK Tax News and Developments - Government White Paper on Customs Bill - On 9 October, the Government published a White Paper setting out its approach to the introduction of a new customs and VAT regime after the UK...more

Morrison & Foerster LLP

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

Proskauer Rose LLP

Tax Round Up - June 2017

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International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more

Proskauer Rose LLP

Tax Round Up - May 2017

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Budget and Finance Bill - General Election – Finance Bill (No.2) 2017 Curtailed - The Finance (No.2) Bill received Royal Assent on 27 April 2017, becoming the Finance Act 2017. However, as a result of Theresa May...more

Proskauer Rose LLP

Tax Round Up - April 2017

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Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

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