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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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13
EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
HMRC manual changes: 29 November 2024
EOT tax relief too narrow, suggests CIOT
Tax reliefs confirmed for special tax sites in Wales
Updated advisory fuel rates published
IHT should apply equally across all assets, says IFS
CASES
Read all
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
IN BRIEF
Read all
Refinitiv: not so clear cut
The complexities of APR and IHT for family farms
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
MOST READ
Read all
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
R (oao Refinitiv Ltd and others) v HMRC
UK signs new double tax treaty with Romania
R (oao Cobalt Data Centre 2 LLP and another) v HMRC