On Wednesday 30 October 2024, the UK government announced changes to the UK taxation of carried interest as part of the 2024 Autumn Budget. Changes were expected following statements made by the Labour Party in the run up to...more
11/12/2024
/ Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Fund Managers ,
HMRC ,
Holding Periods ,
Income Taxes ,
Investment Funds ,
Tax Policy ,
Tax Rates ,
Tax Reform ,
UK
As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (the...more
Welcome to December’s edition of our UK Tax Round Up. This month has seen two interesting decisions on the connections needed for amounts to be taxed as employment income, the latest instalment in the BlueCrest partner...more
1/5/2024
/ Appeals ,
Artificial Intelligence ,
Capital Gains ,
Classification ,
Double Taxation ,
Employment Tax ,
HMRC ,
Limited Liability Company (LLC) ,
Luxembourg ,
Machine Learning ,
Pensions ,
UK
Welcome to May’s edition of our UK Tax Round. This month has been relatively quiet but there were a couple of cases that affect transactions that we see in practice, including an interesting update on what could constitute a...more
Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more
3/29/2023
/ Beneficial Owner ,
Capital Gains ,
Corporate Taxes ,
Double Taxation ,
HMRC ,
Income Taxes ,
Interest Rates ,
OECD ,
Offshore Funds ,
Private Funds ,
Securities ,
Tax Relief ,
Taxation ,
Value-Added Tax (VAT)
Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more
12/6/2022
/ Appeals ,
Bank Taxes ,
Capital Gains ,
Diverted Profits Tax ,
Dividends ,
HMRC ,
Income Taxes ,
Inheritance Tax ,
OECD ,
Transfer Taxes ,
UK
UK COVID-19 Developments -
Extension of support for retail, leisure and hospitality businesses -
Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more
2/8/2021
/ Anti-Avoidance ,
Capital Gains ,
Capital Gains Tax ,
Coronavirus/COVID-19 ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Job Retention Schemes ,
Partnerships ,
Tax Avoidance ,
Tax Exemptions ,
Tax Planning ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
UK Case Law Developments -
Damages on share sales same as on other sales -
In Oversea Chinese Banking Corporation Ltd v ING Bank NV, the Commercial Court has held that the measure of damages for breach of warranty in...more
5/2/2019
/ Acquisitions ,
Capital Gains ,
Controlled Foreign Corporations ,
EU ,
European Commission ,
HMRC ,
International Tax Issues ,
Mergers ,
Private Equity ,
Shareholders ,
State Aid ,
Stock Options ,
UK ,
Warranties
EU developments -
European Court rules that withholding tax exemptions under EU Directives can be denied by abuse of rights principle -
At the end of February, the Court of Justice of the European Union (CJEU) issued...more
4/3/2019
/ Anti-Avoidance ,
Beneficial Owner ,
Capital Gains ,
Controlled Foreign Corporations ,
Court of Justice of the European Union (CJEU) ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Member State ,
OECD ,
Parent Corporation ,
Subsidiaries ,
UK ,
Value-Added Tax (VAT) ,
Withholding Tax
Welcome to the March edition of the Proskauer UK Tax Round Up. As promised, the Spring Statement from the Chancellor focused on the economy and public finances without any major tax announcements. However, a few interesting...more
4/5/2018
/ Anti-Avoidance ,
Capital Gains ,
Controlling Person ,
Corporate Taxes ,
Court of Justice of the European Union (CJEU) ,
Cross-Border ,
Entrepreneurs ,
EU ,
European Commission ,
Federal Budget ,
Foreign Investment ,
GAAR ,
HMRC ,
International Tax Issues ,
Investment Management ,
Limited Partnerships ,
Remuneration ,
Tax Credits ,
Tax Rates ,
UK
UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more
8/25/2017
/ Appeals ,
BEPS ,
Capital Gains ,
Corporate Taxes ,
EBITDA ,
GAAR ,
HMRC ,
Interest Income ,
Investment Funds ,
OECD ,
Tax Deductions ,
Tax Tribunal ,
UK ,
UK Brexit
International Tax Developments -
BEPS Multilateral Convention signed -
On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more
6/16/2017
/ Anti-Avoidance ,
BEPS ,
Capital Gains ,
Corporate Bonds ,
Corporate Taxes ,
Double Taxation ,
EU ,
Film Tax Credits ,
HMRC ,
Investment Funds ,
OECD ,
Tax Deductions ,
UK ,
Value-Added Tax (VAT)
Many people will be familiar with the information gathering and reporting requirements the OECD’s Common Reporting Standard (“CRS”) places on financial institutions. The first exchanges of information between tax authorities...more
9/29/2016
/ Beneficial Owner ,
Capital Gains ,
Common Reporting Standard (CRS) ,
Financial Institutions ,
HMRC ,
Income Taxes ,
Inheritance Tax ,
OECD ,
Tax Evasion ,
Tax Penalties ,
UK
The UK’s 2016 budget was announced on Wednesday 16 March 2016. Although we are waiting for detailed legislation for most of the tax-related announcements, below is a brief summary of some tax points which have caught our...more