DOUBLE-TAXATION-RELIEF

Double taxation relief on foreign dividend income: It is now well established that significant elements of the UK’s tax regime governing the treatment of foreign dividends received by UK companies were incompatible with EU principles of freedom...

Residence and the UK/USA double tax treaty.

Sean Wright

Deepesh Upadhyay

Deepesh Upadhyay and Sean Wright (Eversheds Sutherland) review the Upper Tribunal’s decision in Hargreaves which considers withholding tax and interest payments.

Peter Vaines

It is difficult to see how the test for legitimate expectation set by the Court of Appeal could ever be met.

Mark Middleditch

Mark Middleditch (Allen & Overy) reviews recent developments affecting the City, including the consultation on interest expense and the corporation tax treatment of fines and related payments made by banks.

Macklin v HMRC concerned where a pension plan was established for the purpose of double tax treaty relief. Jonathan Schwarz (Temple Tax Chambers) considers the case and its implications

Alastair Munro Ben Eaton Alastair Munro

Mark Eaton and Alastair Munro suggest that the wording of the draft legislation is too wide and may limit claims to double tax relief in circumstances where that does not appear to be intended

Chris Morgan

Chris Morgan provides an overview of recent developments, including the CJEU decision in the FII GLO, the measures announced in the Autumn Statement to tackle tax avoidance and evasion, proposed amendments to the Parent-Subsidiary Directive and updates from France, Spain and Germany.