The insertion of a US holding company by way of a share-for-share exchange, whereby the shares in an existing UK company (“UKCo”) are transferred to a new US company (“USCo”) in exchange for shares issued by USCo, is commonly...more
Budgets are normally stories of two halves. The first half contains the headline-grabbing tax policy reforms that can be encapsulated in a snappy soundbite in the Budget speech, such as “Chancellor scraps the non-dom regime”....more
Following on from the announcement in the 2018 Budget, from 1 April 2021 non-UK resident purchasers of residential property in England and Northern Ireland will be subject to a new higher rate of SDLT of 2 percentage points...more
Highlighting key tax points coming out of the recent economic update (8 July) delivered by the UK Government: Temporary reduction in stamp duty land tax (“SDLT”) on residential property purchases in England and Northern...more
Here is a brief summary of the measures in the March 2020 Budget which are relevant to the Real Estate sector. Non-UK resident companies with UK property income – As previously announced, non-UK resident companies that...more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2020 on 11 March 2020. The Budget was delivered against a backdrop that very few people could have anticipated at the commencement of the year....more
Finance Bill 2019-2020 - The FB19-20 was published on 11 July. The majority of the matters included have been announced previously with no surprise measures. The draft legislation is now open for consultation. We have...more
UK General Tax Developments - HMRC updates guidance on what constitutes "ordinary share capital" - Following the decision by the First-tier Tribunal (FTT) in Warshaw V HMRC, reported in our UK tax blog earlier this...more
Chancellor George Osborne delivered his fifth coalition Budget today. In a wide-ranging statement, there are a significant number of tax-focused proposals that will make changes across the U.K. tax system. Some of these...more