WITHHOLDING-TAX

Tamar Ruiz

Matthew Mortimer and Tamar Ruiz (Mayer Brown) provide an overview of the tax treatment of derivatives, repo and stock loan transactions for UK companies.

Ceinwen Rees

Serene Ho

Ceinwen Rees and Serene Ho (Kirkland & Ellis) explain why boilerplate clauses exist and why it’s important to check that they are included in the contract.

Mike Lane

Zoe Andrews

The decisions in JTI, Altrad and Burlington are examined in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

Paul Radcliffe

Reinhart Devisscher

After ten compromise texts and two years of political debate, agreement has finally been reached on new rules for EU withholding tax procedures. Paul Radcliffe and Reinhart Devisscher (EY) examine the detail and consider what’s next.

Deepesh Upadhyay

Dominic Robertson

Deepesh Upadhyay (Eversheds Sutherland) and Dominic Robertson (Slaughter and May) examine one of the most important withholding tax cases in years.

Kyle Rainsford

The final CIS regulations and HMRC guidance don’t appear to measure up to the original policy ambition of removing ‘the majority of landlord to tenant payments from the scheme’, writes Kyle Rainsford (Travers Smith).

Mike Lane

Zoe Andrews

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) examines the Court of Appeal decisions in BlackRock and Hargreaves Property, HMRC’s updated guidance on capital-raising arrangements and share exchange clearances, and the OECD’s consolidated commentary on the GloBE model rules.

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.

Tim Sarson

The Advocate General’s opinion on the CFC Finco exemption state aid case, new US regulations and an update on Pillar Two are among the developments in this month’s review by Tim Sarson (KPMG).

Interest on recurring loans constituted yearly interest and UK to UK exemption did not apply.

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