On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of...more
Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...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 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
HMRC has recently updated the guidance relating to the UK’s new qualifying asset holding company (QAHC) tax regime which was introduced from 1 April 2022. The new guidance clarifies HMRC’s approach to whether corporate...more
Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more
6/8/2022
/ Advocate General ,
Corporate Taxes ,
EU ,
Income Taxes ,
International Tax Issues ,
OECD ,
Remuneration ,
Tax Code ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Reform ,
Transfer of Assets ,
UK ,
Value-Added Tax (VAT)
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
UK Case Law Developments -
Income tax consequences of pension-related payments in E.ON v HMRC -
E.ON v HMRC concerned a large UK power and gas supplier, which paid certain lump sum payments, called “facilitation...more
7/6/2021
/ Corporate Taxes ,
Double Taxation ,
Employee Benefits ,
HMRC ,
Income Taxes ,
International Tax Issues ,
OECD ,
Pension Schemes ,
Pensions ,
Tax Avoidance ,
UK
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)
From the beginning of the UK’s first lockdown in March of last year we have reported on the impact of the pandemic on individual and corporate tax residence and permanent establishment risk.
In April 2020 the OECD...more
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)
In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the...more
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)
The Office of Tax Simplification (OTS) has published its first report following its review of certain aspects of the UK’s capital gains tax regime requested by the Chancellor in July this year with the specific purpose of...more
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)
HMRC has updated its guidance on the Coronavirus Job Retention Scheme (CJRS). The changes include the removal of parts of the guidance that related to the application of the CJRS up to 30 June 2020 and to update employers on...more
In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers’ argument that a notice of a tax claim under a tax covenant served on them by the buyer was invalid because it did not...more
8/14/2020
/ Buyers ,
Corporate Taxes ,
International Tax Issues ,
Notice Provisions ,
Private Equity ,
Sellers ,
Share Purchase Agreements ,
Tax Liability ,
Tax Planning ,
Transfer Pricing ,
UK
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)
There has been much discussion over the past year or so about the UK government’s proposal to make changes to the application of the off-payroll working (or IR35) tax rules to private sector end clients so as to shift certain...more
The UK’s First-tier tax tribunal (FTT) has just released an interesting decision considering whether or not expenses incurred by a parent company on advisers’ fees that related to a proposed disposal by a group subsidiary and...more
In light of COVID-19, and in response to requests from European trade associations, the European Commission has published its proposal to amend Directive 2011/16/EU which deals with various strands of administrative...more