UK corporate offence of failure to prevent tax evasion
Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...more
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
Following on from the announcement in the 2018 Budget, from 1 April 2021 non-UK resident purchasers of residential property in England and Northern Ireland will be subject to a new higher rate of SDLT of 2 percentage points...more
Temporary changes to the statutory residence test for inbound COVID-19 workers - The UK Chancellor has written to the chair of the Treasury Select Committee outlining temporary changes to the statutory residence test...more
KEY POINTS - The UK Regulations, finalised on 13 January 2020, will only apply in relation to direct EU taxes. - The Legal Professional Privilege exemption is still unclear. - Penalties have been capped at £5,000. ...more
UK General Tax Developments - Date set for next UK Budget - The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more
Key Points - Coming into force on 1 July 2020, EU DAC6 Regulations will require intermediaries in certain cross-border arrangements to disclose activity to tax authorities. - The DAC will apply retroactively to affected...more
Draft legislation included in the Finance Bill 2019-2020 will potentially make directors and certain other individuals closely connected to a company jointly and severally liable for a company’s tax liabilities that arise...more
Finance Bill 2019-2020 - The FB19-20 was published on 11 July. The majority of the matters included have been announced previously with no surprise measures. The draft legislation is now open for consultation. We have...more
UK General Tax Developments - HMRC updates guidance on what constitutes "ordinary share capital" - Following the decision by the First-tier Tribunal (FTT) in Warshaw V HMRC, reported in our UK tax blog earlier this...more
EU developments - European Court rules that withholding tax exemptions under EU Directives can be denied by abuse of rights principle - At the end of February, the Court of Justice of the European Union (CJEU) issued...more
Streaming of losses on trade succession (Leekes v. HMRC) - This case involved a taxpayer who purchased a business (the "predecessor business") and combined it with their existing business (creating the "enlarged...more
General UK Tax Developments - Enterprise management incentive (EMI) options State Aid approval - We referred in the April UK Tax Round Up to the expiry of the EU's State Aid approval for EMI options. Fortunately, this...more
General UK tax developments - Changes to taxation of termination payments - HMRC has updated its Employment Income Manual to reflect the changes to the taxation of termination payments (including payments in lieu of...more
Welcome to the March edition of the Proskauer UK Tax Round Up. As promised, the Spring Statement from the Chancellor focused on the economy and public finances without any major tax announcements. However, a few interesting...more
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
The shifting sands of the taxation landscape for investment managers continues apace. Just when you perceive an oasis of stability on the horizon, it is revealed to be a mirage by the announcement of yet further changes....more
Employers may want to adjust compensation packages, and high-earners may want to revise their retirement savings strategies. In recent years, the UK government has reduced the lifetime and annual thresholds up to which...more
The Chancellor of the Exchequer’s recent Summer Budget and the related legislation introduced a series of unexpected tax changes along with the promise of further changes to come. Shortly after the Summer Budget was issued...more
The Chancellor of the Exchequer’s Summer Budget on 8th July introduced a series of unexpected tax changes affecting the private equity and investment management industry along with the promise of further changes to come....more