Michael Graham (DLA Piper) sets out the government’s new proposals that would significantly expand the tax base.
On 4 July 2022 the UK government launched a consultation on the UK’s regime for sovereign immunity from UK direct taxation. The UK government’s proposals are to dramatically curtail the existing immunity from UK tax as it applies to sovereign investors (other than with respect to income tax on passive interest income). If the proposals are enacted sovereign investors will now be subject to UK tax on the vast majority of their UK source income and gains including with respect to income and gains on their UK (direct and indirect) real estate investments.
Current position
The UK’s current approach is that sovereign immunity is the principle borne out of international law that one sovereign state cannot impose its law on another sovereign state including with respect to...
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:
Michael Graham (DLA Piper) sets out the government’s new proposals that would significantly expand the tax base.
On 4 July 2022 the UK government launched a consultation on the UK’s regime for sovereign immunity from UK direct taxation. The UK government’s proposals are to dramatically curtail the existing immunity from UK tax as it applies to sovereign investors (other than with respect to income tax on passive interest income). If the proposals are enacted sovereign investors will now be subject to UK tax on the vast majority of their UK source income and gains including with respect to income and gains on their UK (direct and indirect) real estate investments.
Current position
The UK’s current approach is that sovereign immunity is the principle borne out of international law that one sovereign state cannot impose its law on another sovereign state including with respect to...
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:
