Group relief when the link company is non-UK resident
Jackie Wheaton answers a query on whether interest has a UK source, reviewing the key issues following Perrin v HMRC
Peter Stevens summarises the government’s proposals for charging tax on capital gains made by non-residents from disposals of UK residential property
Carolyn Steppler and Jane Scott consider whether it may be easier for some individuals to become non-UK resident under the SRT, now the concept of a ‘clean break’ has been removed
Peter Vaines comments on the operation of CGT on non-residents and ATED
Non-domiciled taxpayers are paying record amounts of tax on income that they generate in the UK, according to figures obtained by the law firm Pinsent Masons.
The monthly round-up by Chris Morgan, with news from the OECD’s BEPS project, two CJEU cases and the latest from France, India and Chile
Stephen Smith sets out the practical lessons from the Paul Daniel case concerning a taxpayer who realised a substantial capital gain whilst purporting to be working full-time abroad
Helen Lethaby reviews recent developments affecting the City, including the consultation on bank levy banding and the surprise Budget announcement on profit transfer anti-avoidance
John Endacott discusses issues arising from the consultation document on CGT and non-residents