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Home
Withholding tax
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Withholding tax
WITHHOLDING-TAX
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.
International review for October 2021
Tim Sarson
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).
The war on holding companies and the return of withholding taxes
Gregory Price
Sarah Ling
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).
The UK asset holding company regime: a quacking idea!
James McCredie
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 player transfers
Paul Pritchard
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.
SKAT and the revenue rule
David Corker
Claire Cross
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.
Property investment: some recent developments
Simon Rose
Kitty Swanson
Kitty Swanson and Simon Rose (Mayer Brown) consider some important tax issues affecting investors in UK real estate.
The taxation of receivables finance transactions
Matthew Mortimer
Emma Noehrbass
Matthew Mortimer and Emma Noehrbass (Mayer Brown) consider some
important tax treatments that can apply to receivables finance transactions.
International tax and treasury issues in 2021
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.
Brexit: tax competition between the UK and the EU27
David Haworth
Alison Dickie
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.
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EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 4 April 2025
Urgent action could be required on non-dom ‘double remittances’
HMRC set out Pillar Two territories
Additional information requirements for creative industry claims updated
Private schools VAT challenge
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
HMRC v Bolt Services UK Ltd
Other cases that caught our eye: 4 April 2025
HMRC v Innovative Bites Ltd and another
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC closing in on tax avoidance (again)
HMRC v Innovative Bites Ltd and another
Excluded property trusts and 6 April 2025
Chancellor hints on digital services tax
Country-by-country reporting goes public