DOUBLE TAX RELIEF

Oliver Marre

The Upper Tribunal’s decision in McCabe shows how difficult it can be to challenge findings of fact when confronted with multi-factorial tests, writes Oliver Marre (5 Stone Buildings).

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) explains that the Upper Tribunal has largely eschewed the FTT’s extensive reliance on UK domestic law cases on ‘purpose’ when determining whether a treaty anti-abuse provision applies.

Kyle Rainsford

Kyle Rainsford (Norton Rose Fulbright) examines the first UK case about the interpretation of a purpose rule in a double tax treaty which extends the recent approach of Blackrock HoldCo 5 to the international fiscal arena.

Irfan Butt

Andrew Seidler

Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.

Charles Osborne

Sara Luder

Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.

Charlotte Anderson

Emily Szasz

Emily Szasz and Charlotte Anderson (Freshfields Bruckhaus Deringer) examine the FTT decision on the interaction between domestic appeals and MAPs which are provided for in double tax treaties.

Francisco Alvarez Silva

Paul Farmer

Paul Farmer and Francisco Alvarez (Joseph Hage Aaronson) analyse the European Commission’s findings and the next steps to be taken.

Expert insight from advisers at Mayer Brown, Pinsent Masons and Clifford Chance.

The new UK/Uruguay double taxation convention, signed in February 2016, entered into force on 14 November 2016. The convention has effect:

The OECD is consulting until 22 April 2016 on a number of specific questions concerning how the new treaty provisions included in the report on Action 6 of the BEPS action plan might affect the treaty entitlement of non-collective investment vehicles (non-CIVs).

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