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Tax Reform United Kingdom

Proskauer - Tax Talks

UK government consults on taxation of carried interest

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The newly elected UK Labour government published its call for evidence (see link here) on the taxation of carried interest on Monday 29 July 2024. This consultation by HM Treasury, cautiously anticipated following statements...more

Proskauer - Tax Talks

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

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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

Mayer Brown

UK Election Bulletin: What would a Labour government mean for businesses?

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Overview - On 22 May 2024, UK Prime Minister Rishi Sunak announced that he had requested permission from King Charles III to dissolve parliament and call a general election. The election will take place on 4 July 2024....more

McDermott Will & Emery

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

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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

Wilson Sonsini Goodrich & Rosati

Changes to Notification Requirements for EMI Options Granted On or After April 6

Companies granting enterprise management incentive (EMI) options to their UK tax resident employees are reminded they must notify HM Revenue & Customs (HMRC) of the awards. Failure to do so means that the option is not EMI...more

McDermott Will & Emery

UK Government Announce Abolition of UK Non-Dom Tax Status and Changes to Come for Inheritance Tax

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On 6 March 2024, the UK government announced the planned abolition of the remittance basis of taxation for UK resident non-domiciliaries from 6 April 2025 onwards for foreign income and gains (FIG). This will be replaced with...more

Proskauer - Tax Talks

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

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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

BCLP

Spring Budget 2024 - Will We See Material Reform?

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Budgets are normally stories of two halves. The first half contains the headline-grabbing tax policy reforms that can be encapsulated in a snappy soundbite in the Budget speech, such as “Chancellor scraps the non-dom regime”....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

Cooley LLP

New UK Legislation Raises Prospect of 1.5% Stamp Tax Charge on Equity Financings

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The Retained EU Law (Revocation and Reform) Act 2023 became law in the UK on 29 June 2023. Broad in scope, the Revocation and Reform Act will, with effect from the end of this year, sweep away a number of European...more

Cadwalader, Wickersham & Taft LLP

UK Tax Administration and Maintenance Day 2023 – Key Tax Consultations

On 27 April 2023, the UK government announced the administrative companion piece to the Budget announced earlier this year, which includes 23 technical tax policy proposals (although some are merely announcements of future...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2023 – Key Tax Measures Impacting Real Estate

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

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

Cadwalader, Wickersham & Taft LLP

Edinburgh Reforms

The UK Government has announced wide ranging reforms to the UK financial services industry, including key tax reforms - On 9 December 2022, the UK Chancellor of the Exchequer, Jeremy Hunt, announced the “Edinburgh...more

Cadwalader, Wickersham & Taft LLP

On the Hunt for Financial Services (and Tax) Reforms

On 9 December 2022, the UK Chancellor of the Exchequer, Jeremy Hunt, announced the “Edinburgh Reforms” of UK financial services. These reforms propose over 30 regulatory reforms that are described as intending to “unlock...more

A&O Shearman

Volatile Reaction to UK “Mini-Budget”

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Bank of England market intervention after presentation of tax package - On 23 September, the new U.K. Government conducted the emergency fiscal event it had scheduled when taking power at the beginning of the month. Many...more

Orrick, Herrington & Sutcliffe LLP

UK Growth Plan ('Mini-Budget') 2022

On 23 September 2022, the UK Government announced a number of significant tax changes in its Growth Plan (widely referred to in the media as a ‘Mini-Budget’). Here are ten key takeaways, of particular relevance to our...more

Dechert LLP

Proposed reforms to sovereign immunity from UK direct tax – Government Consultation

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On 4 July 2022, the government published a consultation document calling for engagement in relation to proposed reforms to clarify who is entitled to benefit from sovereign immunity and also to restrict the availability of...more

Cadwalader, Wickersham & Taft LLP

UK Government Considering Expansion of Investment Transactions List to Include Crypto-Assets

The UK Government has announced a public consultation regarding the possible expansion of the UK’s investment manager exemption (“IME”) to encompass crypto-assets. The IME enables UK-based fund managers to provide...more

Proskauer Rose LLP

UK Tax Round Up - May 2022

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Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

Cadwalader, Wickersham & Taft LLP

A Step Forward for a Corporate Re-domiciliation Regime for the UK

On 12 April 2022, the UK Government published a summary of responses to the consultation on a corporate re-domiciliation regime. We have previously covered the proposed consultation when it was announced as part of the UK...more

Proskauer Rose LLP

UK Tax Round Up - March 2022

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Welcome to the March edition of the Proskauer UK Tax Round Up. In his Spring Statement, the Chancellor focused on measures to alleviate the increasing cost of living and to boost investment in the economy but there were no...more

Proskauer Rose LLP

UK Tax Round Up - February 2022

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Welcome to February’s edition of our UK Tax Round Up. This month’s edition includes updated guidance on the VAT treatment of contractual termination payments, updated HMRC guidance on the assessment of “substantial”...more

Proskauer Rose LLP

UK Tax Round Up - January 2022

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UK Case Law Developments - Contributions to remuneration trust scheme not tax deductible - In Strategic Branding Ltd v HMRC, the First-tier Tribunal (FTT) held that sums contributed by the taxpayer company to a...more

Proskauer Rose LLP

UK Tax Round Up - December 2021

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UK Case Law Developments - Taxpayer treated as receiving distribution in tax avoidance case - We reported on First-tier Tribunal’s (FTT’s) decision in Dunsby v Revenue & Customs in our June 2020 UK Tax Round Up. By way...more

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