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Withholding taxes
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Withholding taxes
WITHHOLDING TAXES
Winners and losers under the non-dom reforms
Emma Chamberlain
Emma Chamberlain OBE (Pump Court Tax Chambers) considers the new regime for non-doms from April 2025 and reviews the likely impact of the changes.
FASTER: a European Withholding Tax Directive
Reinhart Devisscher
Paul Radcliffe
After ten compromise texts and two years of political debate, agreement has finally been reached on new rules for EU withholding tax procedures. Paul Radcliffe and Reinhart Devisscher (EY) examine the detail and consider what’s next.
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Dominic Robertson
Deepesh Upadhyay
Deepesh Upadhyay (Eversheds Sutherland) and Dominic Robertson
(Slaughter and May) examine one of the most important withholding tax
cases in years.
The qualifying private placement exemption: a sticking plaster solution?
Brin Rajathurai
Rob Jones
Brin Rajathurai and Robert Jones (Freshfields Bruckhaus Deringer) review a useful exemption that is sometimes overlooked.
The new Luxembourg/UK double tax treaty
Irfan Butt
Andrew Seidler
Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.
Towards a common European withholding framework
David Wren
Reinhart Devisscher
Paul Radcliffe
Paul Radcliffe, David Wren and Reinhart Devisscher (EY) consider the next steps for the EU to develop this model, and some key areas which may need to be contemplated in light of the European Commission’s upcoming consultation.
The new income tax charge on offshore receipts in respect of intangibles
Steve Edge
Dominic Robertson
While the UK’s new digital services tax hogged the limelight in the recent Budget, much less attention was paid to the fact that the proposed extension of withholding tax on royalties paid to tax havens (announced at the previous Budget) was...
Hargreaves Lansdown and platform ‘loyalty payments’
Paul Shaw
Paul Williams
Paul Shaw and Paul Williams (Bryan Cave Leighton Paisner) examine a recent tribunal decision on the nature of annual payments and platform agreements.
Tax themes in acquisition financing
Jonathan Cooklin
Dominic Foulkes
Dominic Foulkes and Jonathan Cooklin (Davis Polk) consider some developments on the taxation of lending into UK acquisition finance structures.
FB 2016: Withholding tax on royalties
Anne Fairpo
The changes in the current Finance Bill will bring rather more intellectual property royalties into the scope of withholding tax, as Anne Fairpo (Temple Tax Chambers) explains.
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EDITOR'S PICK
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
1 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
2 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
3 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
4 /7
2024: that was the year that was
Jemma Dick
5 /7
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
6 /7
The tractor tax
Stuart Maggs
7 /7
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
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
The tractor tax
Stuart Maggs
NEWS
Read all
US ‘rejects very nature’ of UN tax talks
HMRC consulting on MTT and DTT draft guidance
HMRC data-collection powers
Retained EU law: further changes
CIOT urges Government to rethink IHT pensions proposals
CASES
Read all
M Ashley v HMRC
AAA Oriental Ltd v HMRC
Other cases that caught our eye: 7 February 2025
Bryan Robson Ltd v HMRC
Hoopla Animation Ltd (formerly known as Daisy Boo and Monkey Too Ltd) v HMRC
IN BRIEF
Read all
Themes in UK corporate tax disputes for 2025 (and beyond)
JVs and the top-up taxes: does HMRC’s draft guidance bring clarity?
Reflections on the Budget fallout – three months on
BlueCrest: the CA ruling on Condition B
Tweaking the Temporary Repatriation Facility
MOST READ
Read all
Global by Nature Ltd v HMRC
Tweaking the Temporary Repatriation Facility
Bryan Robson Ltd v HMRC
Pillar Two one year on: what have we seen and where are we going?
HMRC v Sonder Europe Ltd