Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the...more
3/10/2025
/ Anti-Avoidance ,
Canada ,
Capital Markets ,
Carried Interest ,
Corporate Taxes ,
HMRC ,
International Tax Issues ,
Tax Planning ,
Tax Returns ,
Transfer Pricing ,
UK
Welcome to the January 2025 edition of our UK Tax Round Up. This month has seen a very interesting decision of the Court of Appeal on the significant influence test in the salaried member rules and decisions on the tax...more
Welcome to the November 2024 edition of our UK Tax Round Up. This month has seen publication of the Finance Bill 2024-25 and interesting cases on the loan relationship unallowable purpose test and the extent that tax applies...more
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 the September edition of the UK Tax Round Up. This month has seen interesting decisions on the salaried members rules, the scope of arrangements for the CGT rollover main tax avoidance purpose test and the...more
10/12/2023
/ Compensation ,
Film Industry ,
GAAP ,
HMRC ,
Investment ,
Private Limited Companies ,
Subsidies ,
Tax Avoidance ,
Tax Deductions ,
Tax Exemptions ,
Tax Planning ,
UK
Welcome to June’s edition of the UK Tax Round Up. This month’s edition features a summary of HMRC’s recent guidance on QAHCs and credit funds, the publication of the new UK/Luxembourg double tax treaty and the delay to the...more
Welcome to the March edition of the Proskauer UK Tax Round Up. In his Spring Statement, the Chancellor focused on measures to alleviate the increasing cost of living and to boost investment in the economy but there were no...more
Welcome to February’s edition of our UK Tax Round Up. This month’s edition includes updated guidance on the VAT treatment of contractual termination payments, updated HMRC guidance on the assessment of “substantial”...more
Welcome to November’s edition of the UK Tax Round Up. This month has seen publication of the Finance Bill 2021-22 (what will become the Finance Act 2022) including draft legislation for the basis period reform, UK asset...more
12/3/2021
/ Corporate Taxes ,
HMRC ,
Holding Companies ,
Income Taxes ,
International Tax Issues ,
IR35 ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
UK ,
Withholding Tax
In Fashion on the Block Limited v HMRC, the First-tier Tribunal (FTT) has allowed the taxpayer’s appeal against HMRC’s decision not to allow the taxpayer company to issue seed enterprise investment scheme (SEIS) certificates...more
In Claims Advisory Group v HMRC,
The Upper Tribunal (UT) has confirmed that the service of claiming compensation on behalf of third parties for mis-sold payment protection insurance (PPI), is subject to VAT and not exempt...more
UK General Tax Developments -
Stamp Duty and COVID-19 -
Since the start of the first UK lockdown in March 2020, HMRC has been accepting that documents can be stamped electronically. HMRC has now confirmed that, where...more
UK Case Law Developments -
Tax avoidance motive did not prevent availability of share for share exchange treatment -
In Euromoney Institutional Investor plc v HMRC, the FTT held that the share for share exchange...more
Spring Budget and Tax Day -
After months of speculation about the possibility that capital gains tax (CGT) rates would be increased in the Spring Budget, both it and the government’s follow up “Tax Day” on 23 March passed...more
UK Case Law Developments -
EIS relief not available for shares carrying preferential rights -
The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more
3/10/2021
/ Corporate Taxes ,
EU ,
European Commission ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
OECD ,
Private Equity ,
Tax Avoidance ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
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)
COVID-19 Developments -
Tax exemptions for coronavirus antigen costs -
Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more
1/5/2021
/ Corporate Taxes ,
HM Treasury ,
HMRC ,
Holding Companies ,
Income Taxes ,
International Tax Issues ,
OECD ,
Private Equity ,
Tax Planning ,
Transfer Pricing ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
Extension of support for employed and self-employed workers -
On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more
12/3/2020
/ Capital Gains Tax ,
Corporate Taxes ,
EU ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Job Retention Schemes ,
Tax Avoidance ,
Tax Exemptions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
UK Prime Minister’s statement on COVID-19 -
On 31 October, the Prime Minister announced a number of measures designed to slow down the spread of COVID-19 to last for four weeks from 4...more
11/9/2020
/ BEPS ,
Corporate Taxes ,
European Commission ,
Fund Managers ,
HMRC ,
Income Taxes ,
Insurance Industry ,
International Tax Issues ,
OECD ,
OTS ,
Pension Schemes ,
Tax Authority ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
HMRC updates its trading activities guidance -
HMRC has updated its guidance at BIM48000 regarding how legislation and case law should be applied where a business makes changes to its...more
7/1/2020
/ Corporate Taxes ,
Cross-Border Transactions ,
Guidance Update ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Loan Market Association ,
Reporting Requirements ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 developments -
Proposed deferral of DAC6 and DAC2 -
The European Commission has published a draft directive proposing a three month delay to the deadlines for certain information disclosures under the EU...more
6/3/2020
/ Coronavirus/COVID-19 ,
Corporate Taxes ,
EU ,
European Commission ,
HMRC ,
Income Taxes ,
Infectious Diseases ,
International Tax Issues ,
Personal Protective Equipment ,
Tax Deductions ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
Temporary changes to the statutory residence test for inbound COVID-19 workers -
The UK Chancellor has written to the chair of the Treasury Select Committee outlining temporary changes to the statutory residence test...more
5/12/2020
/ Anti-Avoidance ,
Corporate Taxes ,
Digital Services Tax ,
EU ,
European Court of Justice (ECJ) ,
Guidance Update ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK General Tax Developments -
HMRC updates to the private sector IR35 rules -
On 7 February 2020, HMRC confirmed that the new private sector IR35 rules will only apply to payments made for services provided on or...more
3/5/2020
/ Collective Investment Schemes ,
Corporate Taxes ,
Employer Liability Issues ,
Foreign Investment ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Private Equity ,
State Aid ,
Tax Planning ,
UK ,
UK Brexit ,
Value-Added Tax (VAT)
UK Case Law Developments -
Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation -
In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more
10/31/2019
/ Arm's Length Principle ,
Corporate Taxes ,
EU ,
European Commission ,
GAAR ,
HM Treasury ,
HMRC ,
Income Taxes ,
International Tax Issues ,
OECD ,
Private Equity ,
Share Purchase Agreements ,
Tax Planning ,
Transfer Pricing ,
UK ,
Value-Added Tax (VAT)
Case Law Developments -
Place of supply for VAT purposes -
The recent case of American Express Services Europe Limited (AESEL) v HMRC is a useful reminder of the well-established two-stage approach to determining the...more
10/7/2019
/ Acquisitions ,
Corporate Taxes ,
EU ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Mergers ,
Private Equity ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)