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Withholding tax
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WITHHOLDING-TAX
Tax aside? Private investment fund side letters
Deepesh Upadhyay
Benjamin Shem-Tov
Ben Jones
Ben Jones, Deepesh Upadhyay and Benjamin Shem-Tov (Eversheds
Sutherland) examine the increasing use of side fund letters in a private
investment funds context and the associated most favoured nations process.
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).
Beneficial entitlement in Hargreaves: is Indofood now part of UK domestic law?
Dominic Robertson
The Upper Tribunal in
Hargreaves
effectively seeks to import the Indofood concept of beneficial entitlement into domestic law. Dominic Robertson (Slaughter and May) examines the practical uncertainties this creates and questions whether the decision was correctly decided.
Withholding tax: Hargreave-ances
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.
Investment into and expansion within the UK: acquisition planning
Helena Kanczula
When structuring a UK acquisition, there are a myriad of tax issues to
consider, as Helena Kanczula (BKL) explains.
Tax and the City review for April 2022
Zoe Andrews
Mike Lane
The Supreme Court decision in
NCL Investments Ltd
and the Court of Appeal decision in
Skatteforvaltningen
are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Dicey Rule 3: the Court of Appeal’s decision in Skat v Solo
Dilpreet K. Dhanoa
Philip Baker KC
The Court of Appeal has upheld SKAT’s claims. Philip Baker QC and Dilpreet K. Dhanoa (Field Court Tax Chambers) analyse whether, from a legal and international tax perspective, this was the correct decision.
Tax and the City review for January 2022
Zoe Andrews
Mike Lane
The consultation on hedging risks for future share transactions and the FTT
decision in
Hargreaves
are some of the recent developments reviewed by
Mike Lane and Zoe Andrews (Slaughter and May).
Hargreaves: withholding tax on rollover funding under scrutiny
Dominic Stuttaford
Sofia Casselbrant
Dominic Stuttaford and Sofia Casselbrant (Norton Rose Fulbright) consider the FTT’s decision in
Hargreaves
and its implications for the UK withholding tax regime.
The UK’s new qualifying asset holding company regime
Elena Rowlands
Ian Zeider
Emily Clark
Emily Clark, Elena Rowlands and Ian Zeider (Travers Smith) give an overview of, and their verdict on, the QAHC legislation in the Finance Bill.
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EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
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
NEWS
Read all
HMRC manual changes: 1 November 2024
Chancellor targets businesses with CGT and IHT reforms
Spotlight on LLPs and disguised remuneration arrangements
New HMRC guidance for taxpayers on rental income
Land transaction tax in Wales: relief for special tax sites
CASES
Read all
GCH Corporation Ltd and others v HMRC
Abbeyford Caravan Company (Scotland) Ltd v HMRC
S Lefort v HMRC
Other cases that caught our eye: 1 November 2024
R (oao Rettig Heating Group UK Ltd (in liquidation)) v HMRC
IN BRIEF
Read all
Autumn Budget 2024: a tax hike with familiar terrain
Autumn Budget 2024: tax on corporates
Autumn Budget 2024: private equity reforms - a mixed bag
Autumn Budget 2024: non-doms - the end of an era
Autumn Budget 2024: nothing too scary about CGT
MOST READ
Read all
‘Arrangements’ that disqualify new EMI option grants
A tale from the frontline of SDLT
Pillar Two and funds: there is no panacea
One minute with... Paul Rosser
Government to consult on new corporate re-domiciliation regime