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IP withholding tax: is the UK overreaching?

The UK reaches out, but is this the right time and in the right way? Steve Edge (Slaughter and May) examines the latest position on IP withholding tax.
 
Imagine the scene – a Treasury official is asking how the government can get more UK tax base. ‘We have taxed the banks as much as we can haven’t we?’ he asks. ‘No I know what we will do with the banks operating through branches in London and funding those branches in part through the proceeds of retail deposits taken by their headquarters in New York. We’ll deem the interest payments paid on those deposits by the New York office to the UK to have a UK source. (After all even though London had nothing to do with taking or managing those deposits the funds are really being used here aren’t they?) And then we’ll...

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