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Double taxation
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Double taxation
DOUBLE-TAXATION
Disguised investment management fees: some international aspects
Robert Langston
Robert Langston (Saffery) explains why it is necessary to consider international tax principles, such as entity classification and transfer pricing, alongside the disguised investment management fee rules.
The CIR and related party guarantees: a case study for a privately owned UK group
Robert Langston
Robert Langston (Saffery) provides a practical case study on the operation
of the corporate interest restriction where related party guarantees and
withholding tax issues are involved.
Clipperton revisited: open questions
Oliver Marre
Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and
its implications going forward.
G Haworth and others v HMRC
Upper Tribunal finds FTT correctly tested place of effective management of trusts.
US limited liability corporations: updated HMRC guidance
Sebastian Prichard Jones
Andrew Crozier
HMRC’s updated guidance on the treatment of profits arising within, and
distributions from, US LLCs is unsatisfactory in a number of respects, write
Sebastian Prichard Jones and Andrew Crozier (Macfarlanes).
Tax and the City review for November 2023
Mike Lane
Zoe Andrews
Target Group
,
Vermilion
and changes to HMRC’s guidance on the double tax
treaty passport scheme are among the developments examined by Mike Lane
and Zoe Andrews (Slaughter and May).
Transfer pricing and intangibles: are all the issues priced in?
James Anderson
Alex Rigby
James Anderson and Alex Rigby (Skadden) examine HMRC’s package of
proposed transfer pricing reforms, and consider how they might assist with
existing uncertainty and double taxation disputes.
Judicial developments in recent treaty cases
Constantine Christofi
David Goldberg QC
Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).
Reviewing HMRC’s consultation on transfer pricing reform
Bezhan Salehy
Deep Shah
Bezhan Salehy and Deep Shah (Macfarlanes) review the government’s extensive package of proposals that touch most areas of the UK’s transfer pricing, permanent establishment and diverted profits tax legislation.
GE Financial, treaty residence, and the meaning of ‘business’
Kyle Rainsford
Kyle Rainsford (Travers Smith) examines the ramifications of the Upper Tribunal’s decision.
Go to page
of
5
EDITOR'S PICK
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
1 /7
SDLT: gardens, grounds and grazing
Max Schofield
2 /7
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
3 /7
A capital blow for deducting management expenses
Kyle O'Sullivan
4 /7
VAT on private school fees: 10 takeaways
Etienne Wong
5 /7
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
6 /7
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
,
Gabrielle Van der Haegen
7 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
A capital blow for deducting management expenses
Kyle O'Sullivan
VAT on private school fees: 10 takeaways
Etienne Wong
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
NEWS
Read all
HMRC manual changes: 13 September 2024
Budget Responsibility Bill enacted
ECJ overturns General Court's judgment in Apple State Aid case
Chancellor confirms business tax roadmap will be in Budget
Sunset date for EIS and VCT relief
CASES
Read all
Barclays Service Corporation and another v HMRC
Janet Bray Ltd v HMRC
Equity Advisory Ltd and another v HMRC
Other cases that caught our eye: 13 September 2024
HMRC v S&L Barnes Ltd
IN BRIEF
Read all
Self’s assessment: Business Tax Roadmap
Recognising ‘imported losses’ under the loan relationship rules
Suspended penalties
R&D claim notification
The everyday economy
MOST READ
Read all
HMRC manual changes: 13 September 2024
Budget Responsibility Bill enacted
Self’s assessment: Business Tax Roadmap
Suspended penalties
The last word on tax appeals