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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
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
1 /7
Freebies
David Whiscombe
2 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
3 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
4 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
5 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
6 /7
SDLT: gardens, grounds and grazing
Max Schofield
7 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
NEWS
Read all
HMRC manual changes: 25 October 2024
Government to consult on new corporate re-domiciliation regime
HMRC revamp guidance on EMI independence test
HMRC confirm delay to new employer reporting requirement
Special tax sites designated in Wales
CASES
Read all
R (oao Rettig Heating Group UK Ltd (in liquidation)) v HMRC
R (oao Fluid Systems Technologies (Scotland) Ltd and others) v HMRC
Other cases that caught our eye: 25 October 2024
Panayi v HMRC
BTR Core Fund JPUT v HMRC
IN BRIEF
Read all
‘Arrangements’ that disqualify new EMI option grants
A tale from the frontline of SDLT
Bed and breakfasting before the Budget?
NICs and the Budget
Non-dom reforms: shaping the regime
MOST READ
Read all
Panayi v HMRC
Home and away: how to go non-resident after McCabe
HMRC update ERS guidance for Vermilion
BTR Core Fund JPUT v HMRC
ISAs and fractional shares