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Tax Liability HMRC Corporate Taxes

Latham & Watkins LLP

Restructuring Plans and Tax Liabilities A More Assertive HMRC

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Companies must approach HMRC with suitable care when proposing a restructuring plan, mindful of lessons learned from recent case law. Ever since unpaid taxes due to HMRC were “crammed down” pursuant to a restructuring plan...more

Latham & Watkins LLP

Directors Duties Post-Sequana More Light at the End of the Tunnel

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A recent decision has helped to frame the tests articulated by the Supreme Court in Sequana. The Supreme Court’s landmark decision in Sequana[2022] UKSC 25.leaves many unanswered questions, and finding a common thread...more

Proskauer Rose LLP

UK Tax Round Up - June 2022

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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

Proskauer - Tax Talks

HMRC Clarifies Application of QAHC Regime to Corporate Lending Vehicles

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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

Proskauer Rose LLP

UK Tax Round Up - May 2021

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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

Jones Day

Restoration of Crown Preference and Erosion of the English Floating Charge

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With effect from December 1, 2020, Her Majesty's Revenue and Customs ("HMRC") ranks ahead of floating charge holders and unsecured creditors with respect to recovering certain pre-insolvency taxes from an insolvent business...more

Dechert LLP

UK Asset Holding Companies – Alternative Credit Funds: A Chance to Shape the Future

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The UK government has published a response to the consultation announced last year in relation to the possible introduction of a new tax advantaged regime for UK asset holding companies (AHC) used in the context of...more

Jones Day

The UK’s Digital Services Tax: Where Are We Now?

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Current Status: The UK Government is moving ahead with its implementation of the Digital Services Tax ("DST") despite concerns raised by the United States and the Organisation of Economic Co-operation and Development ("OECD")...more

Proskauer Rose LLP

UK Tax Round Up - December 2019

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UK Case Developments - IR35 – no mutuality of obligation to create a contract of employment - RALC Consulting Ltd v HMRC has provided the First-tier Tribunal (FTT) with another opportunity to consider the application...more

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