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Tax Deductions United Kingdom HMRC

BCLP

A Capital Blow for Deducting Management Expenses

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The Supreme Court confirmed in Centrica Overseas Holdings Ltd v HMRC that the tests for trading and management expenses of a capital nature are the same. The decision also confirms that once a company has decided in principle...more

Cadwalader, Wickersham & Taft LLP

Examining "Purpose"

The recent Upper Tribunal (“UT”) decision in JTI Acquisitions Company (2011) Ltd v HMRC [2023] UKUT 194 (TCC) has further illuminated the interpretation and application of the “unallowable purposes” rule in the UK’s loan...more

Proskauer Rose LLP

UK Tax Round Up - September 2023

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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

Proskauer Rose LLP

UK Tax Round Up - July 2023

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Welcome to July’s edition of our UK Tax Round Up. This month has seen a number of interesting tribunal decisions, including the denial of double tax relief and of employee expense deductions and the taxation on loans to a...more

Cadwalader, Wickersham & Taft LLP

A Toothless Tax Avoidance Scheme: M Northwood v HMRC

The UK’s First-tier Tribunal (“FTT”) has denied a taxpayer a deduction for contributions to a remuneration trust on the basis that such payments did not give rise to an expense under generally accepted accounting principles...more

BCLP

Spring Budget 2023 - tax impact on the real estate sector

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Underneath the headline points, the Budget contained a number of measures designed to fulfil the Chancellor’s objective of encouraging growth and investment. There was broadly good news for those investing in UK real estate....more

Cadwalader, Wickersham & Taft LLP

HMRC v BlackRock Holdco 5 LLC Throws a Spotlight on UK Transfer Pricing and the ‘Unallowable Purposes’ Rule

A decision in late-July 2022 of the UK’s Upper-tier Tax tribunal (“UTT”) has held that interest recognized by a UK resident company on loan notes issued to its parent was non-deductible under the UK transfer pricing rules, as...more

Hogan Lovells

Potential additional hurdle to clear if interest on intra-group debt is to be tax deductible in the UK

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In applying the UK’s transfer pricing rules, tax advisers have to think beyond the amount of the debt and the interest rate to get comfortable that an intra-group loan is going to be tax deductible. Following a recent case,...more

Proskauer Rose LLP

UK Tax Round Up - May 2020

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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

Hogan Lovells

Budget 2020: real estate tax changes

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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

BCLP

UK makes amendments to regime for agents withholding tax on rent paid to non-resident corporate landlords

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The Government has amended the existing non-resident landlord scheme regulations (S.I. 1995/2902) in readiness for the transition to corporation tax for non-resident corporate landlords from 6 April 2020. The changes impact...more

Proskauer Rose LLP

UK Tax Round Up - August 2017

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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

Proskauer Rose LLP

Tax Round Up - June 2017

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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

Proskauer Rose LLP

Tax Round Up - April 2017

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Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Proskauer Rose LLP

UK Summer Budget 2015 – Key Issues for Asset Managers and Non-UK Domiciled Individuals

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On 8th July 2015, the UK Government announced several changes to UK tax legislation that will affect those holding carried interest in fund structures which utilise at least one partnership (including a limited partnership),...more

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