RESIDENCE

Heather Self

In our continuing series, Heather Self reviews tax issues that make the headlines in the national press. This week, the impact of the new US proposals on international tax reform.

Edward Reed

Tristan Honeyborne

This month’s private client update, by Edward Reed and Tristan Honeyborne (Macfarlanes).

Catrin Harrison Hugh Gunson Dominic Lawrance

Catrin Harrison, Dominic Lawrance and Hugh Gunson (Charles Russell Speechlys) examine an Upper Tribunal decision that is disappointing for taxpayers and removes a strategic weapon for anyone faced with a domicile enquiry.

Laura Hoyland

Elizabeth Emerson

Laura Hoyland and Elizabeth Emerson (White & Case) explain the various bear-traps for a foreign company proposing to do business in the UK.

Gregory Price Ashley Greenbank Rhiannon Kinghall Were

Experts at Macfarlanes examine the latest pronouncements from HMRC and the OECD on the impact of Covid-19 on company tax residence.

Andrew Goodman Erika Jupe Veronica McMahon

Experts at Osborne Clarke consider the tax implications.

Styliani Ntoukaki

Michael Anderson

Michael Anderson and Styliani Ntoukaki (Joseph Hage Aaronson) explain how the Greek government is seeking to attract wealthy foreigners by introducing a new non-dom regime.

Penny Van den Brande

Ashley Greenbank

Ashley Greenbank and Penny Van den Brande (Macfarlanes) consider the UK tax consequences for businesses considering moving assets or functions out of the UK, whether by a change of residence of a UK company, the insertion of a new, non-UK, holding company or the relocation of specific assets and functions

Julian Feiner

Julian Feiner (Clifford Chance) discusses the taxpayers' resounding victory at the Upper Tribunal in the company residency case of Development Securities plc and others v HMRC.

Siv Devakumar

Simon Skinner

What are the ORIP rules? What are they seeking to achieve? It is perhaps surprising that so little has been said about the offshore receipts in respect of intangible property (ORIP) rules. After all, these are internationally unique, transformed...

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