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Dividend
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Dividend
DIVIDEND
Corporation tax rate complexities for corporate LLP members
Emma Rawson
The corporation tax rates rules can be complex. Emma Rawson (ATT) looks at the particular difficulties facing corporate members of LLPs.
Clipperton revisited: open questions
Oliver Marre
Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and
its implications going forward.
S Clipperton and another v HMRC
Court of Appeal confirms that dividend replacement scheme failed.
UK holding companies: why they are still holding strong?
Artem Vasyutin
Sophie Hatton
As a territorial tax regime, the UK has a number of benefits, which have only increased over the last two decades, write Artem Vasyutin and
Sophie Hatton (
Deloitte).
Timing of dividends for income tax purposes
Dominic Stuttaford
Aiden Hepworth
Two recent cases provide a reminder of the extent to which taxation outcomes can depend on other areas of law and demonstrate that HMRC will not be limited to ‘pure’ tax law arguments on appeal, write Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright).
The new Luxembourg/UK double tax treaty
Irfan Butt
Andrew Seidler
Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.
Remuneration trusts: the importance of facts
Constantine Christofi
Adam Craggs
Adam Craggs and Constantine Christofi (RPC) examine the First-tier Tribunal decision in
Marlborough DP Ltd v HMRC
that suggests the shortcomings in HMRC’s general approach following
Rangers
.
The FII group litigation: the end of the beginning or the beginning of the end?
Cristiana Bulbuc
Lee Ellis
The Supreme Court has handed down its third judgment in the long-running
FII GLO
case. Lee Ellis and Cristiana Bulbuc (Stewarts) consider how we got here and what this means for taxpayers with unresolved issues concerning overseas dividend taxation.
Tax on establishing a business in Australia
Paula Tallon
Siobhan Sellick
Now that Australia and UK have signed their trade agreement, Paula Tallon and Siobhan Sellick (Prosperity Advisers Group) explain what Australian taxes UK companies will encounter when establishing a business presence there.
Private client briefing for March 2017
Andrew Goldstone
Helen Cox
Andrew Goldstone and Helen Cox (Mishcon de Reya) review the latest tax
developments that matter affecting private clients.
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EDITOR'S PICK
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
1 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
2 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
3 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
4 /7
2024: that was the year that was
Jemma Dick
5 /7
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
6 /7
The tractor tax
Stuart Maggs
7 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
The tractor tax
Stuart Maggs
NEWS
Read all
HMRC manual changes: 31 January 2025
Consultation on HMRC statistics publications
Government launches independent loan charge review
Finance Bill amended, but further changes expected
LTT relief extended to Anglesey tax sites
CASES
Read all
Bryan Robson Ltd v HMRC
Hoopla Animation Ltd (formerly known as Daisy Boo and Monkey Too Ltd) v HMRC
Other cases that caught our eye: 31 January 2025
HMRC v BlueCrest Capital Management (UK) LLP
ScottishPower (SPCL) Ltd and others v HMRC
IN BRIEF
Read all
BlueCrest: the CA ruling on Condition B
Tweaking the Temporary Repatriation Facility
ScottishPower: payments under settlement agreements
Balancing growth and taxes: the corporate tax roadmap
The increased interest rate on late payments
MOST READ
Read all
Global by Nature Ltd v HMRC
Tweaking the Temporary Repatriation Facility
Bryan Robson Ltd v HMRC
Pillar Two one year on: what have we seen and where are we going?
HMRC v Sonder Europe Ltd