Since I wrote my last column we have had a Budget a Finance Act and the dissolution of Parliament in preparation for the General Election. After this rush of activity we are now unlikely to see any further developments on some of the longer term strategic changes to the UK international tax system currently under discussion such as CFC reform the Patent Box and taxation of foreign branches until the next Government has settled in. However the Courts are still in action and overseas tax authorities are unaffected by the UK election so there is still plenty to write about.
One interesting development that non-UK banks and other corporate or opaque overseas lenders will potentially benefit from are new HMRC proposals to introduce a fast-track treaty relief 'passport' scheme for withholding tax. Most readers will be...
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Since I wrote my last column we have had a Budget a Finance Act and the dissolution of Parliament in preparation for the General Election. After this rush of activity we are now unlikely to see any further developments on some of the longer term strategic changes to the UK international tax system currently under discussion such as CFC reform the Patent Box and taxation of foreign branches until the next Government has settled in. However the Courts are still in action and overseas tax authorities are unaffected by the UK election so there is still plenty to write about.
One interesting development that non-UK banks and other corporate or opaque overseas lenders will potentially benefit from are new HMRC proposals to introduce a fast-track treaty relief 'passport' scheme for withholding tax. Most readers will be...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
