DOUBLE-TAXATION

Claire Weeks and Dominic Condé-Cole (Maurice Turnor Gardner) explain why it’s now a very good time to consider de-enveloping in order to mitigate the increasing double tax costs.

Will Egan

Graham Samuel-Gibbon

Graham Samuel-Gibbon and Will Egan (Taylor Wessing) consider HMRC's updated list of double tax treaties and the tax implications for groups with entities in those jurisdictions.

David Pett

David Pett (Temple Tax Chambers) looks at the information requirements and how the disguised remuneration rules apply to the loan charge, and to later steps, if no settlement of earlier liabilities has been made with HMRC.

Jackie Wheaton

How can UK companies which do not have foreign permanent establishments obtain relief for state or nexus taxes charged by foreign territories?

Jackie Wheaton (Moore Stephens) reviews the key points.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.

Liz Pierson

There are provisions tackling disguised remuneration in the Finance Act 2017, the Finance Bill currently going through Parliament, and for inclusion in the next Finance Bill. Liz Pierson (Squire Patton Boggs) reviews the legislative landscape.

Liesl Fichardt

Chintan Chandrachud

The new directive makes important changes to the regime for resolving double taxation disputes, write Liesl Fichardt and Chintan Chandrachud (Quinn Emanuel Urquhart & Sullivan).

James Tryfonos

Eloise Walker

Eloise Walker and James Tryfonos (Pinsent Masons) provide a guide to the potential tax pitfalls in respect of interest rate swaps.

Jeremy Webster

Jamie Robson

Jeremy Webster and Jamie Robson (Pinsent Masons) consider how the MLI amends existing DTTs, and examine whether the principal purpose test would apply in a given scenario.