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WITHHOLDING-TAX


Progress on BEPS 2.0, the EU’s public CBCR directive and plans for a new EU withholding tax system are among recent developments examined by Tim Sarson (KPMG).
BEPS 2.0 and ATAD 3 represent the latest challenge to the tax status of holding companies, renewing focus on issues of substance and withholding taxes, write Gregory Price and Sarah Ling (Macfarlanes).
James McCredie (Macfarlanes) reviews a hugely welcome new regime, but explains there are still some ‘shoot in foot’ opportunities that it is to be hoped the government and HMRC will resist.
Football may not be coming home, but there is always tax to consider. Paul Pritchard (FTI Consulting) reviews the tax issues on player transfers, including the reinvestment relief on players, employment tax issues with buyout and the withholding of tax on image rights payments.
The ‘revenue rule’ is a longstanding legal principle that the courts of one country will not enforce the tax laws of another country. It was recently tested in the High Court, as David Corker and Claire Cross (Corker Binning) report.
Kitty Swanson and Simon Rose (Mayer Brown) consider some important tax issues affecting investors in UK real estate.
Matthew Mortimer and Emma Noehrbass (Mayer Brown) consider some important tax treatments that can apply to receivables finance transactions.
Card image Andrew Cotterill John Webb Mairead Murphy
Interest deductibility, foreign exchange, withholding taxes... John Webb, Andrew Cotterill and Mairead Murphy (PwC) review the key UK tax considerations for financing transactions and global treasury functions.
Alison Dickie and David Haworth (Freshfields Bruckhaus Deringer) consider whether the Brexit deal paves the way for a low-tax and less regulated UK tax environment. 
Card image Gavin Orpwood Louise Keegan Hannah McKenzie
Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the tax risks to international business operating models.
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