Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind
The Supreme Court confirmed in Centrica Overseas Holdings Ltd v HMRC that the tests for trading and management expenses of a capital nature are the same. The decision also confirms that once a company has decided in principle...more
In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more
Summary - On 5 July 2023 the English High Court handed down its judgment to In the matter of Prezzo Investco Limited and In the matter of the Companies Act 2006 [2023] EWHC 1679 (Ch), another case (hot on the heels of The...more
Welcome to the second edition of our Horizon Scan, where we focus on some of the principal recent and expected developments and changes that we expect to be of interest to those in the non-listed funds sector. We have grouped...more
This was an appeal against the High Court decision in Dodika Ltd & Ors v United Luck Group Holdings Limited from August 2020 (see our Tax Blog on this). The case concerns the question of whether the notice given by the buyer...more
Coinciding with the end of the UK-EU Brexit transition period, the United Kingdom has dramatically reduced the scope of DAC 6 reporting obligations in the United Kingdom. ...more
Our International Tax Transparency Update will cover DAC6, the UK’s Trust Registration Service and other global registration requirements that may be relevant for businesses. The importance of these requirements cannot be...more
UK COVID-19 Developments - UK Prime Minister’s statement on COVID-19 - On 31 October, the Prime Minister announced a number of measures designed to slow down the spread of COVID-19 to last for four weeks from 4...more
DAC6 summary - Council Directive 2018/822 – known as DAC6 – is the sixth amendment to the EU Directive on Administrative Cooperation 2011/16/EU. DAC6 is aimed at providing the tax authorities with a “warning system” in...more
In the recent case of Melford Capital General Partner Ltd v HMRC, the FTT concluded that a UK GP was entitled to full recovery of input VAT incurred on the establishment and operational costs of a UK LP Fund of which it was...more
Yesterday, the UK tax authorities published a note finally clarifying the registration requirements imposed on such investors. In summary: A non-UK resident corporate investor making a direct or indirect sale of UK...more
HMRC announced today the introduction of their new Profits Diversion Compliance Facility (PDCF). This is a way for multinationals to take the initiative and explain their legal and operational structures before HMRC launch...more