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Tax Liability HMRC Double Taxation

Cadwalader, Wickersham & Taft LLP

Burlington: Good News for the Secondary Debt Market

In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) (“Burlington”) the Upper Tribunal (“UT”) dismissed HMRC’s appeal, holding that the First-tier Tribunal (“FTT”) was right to conclude that the anti-abuse provision...more

Proskauer Rose LLP

UK Tax Round Up - October 2022

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Welcome to the October edition of the UK Tax Round Up. October has been an extraordinary month in the UK, with political turbulence triggering reversals of many of the tax policies announced by the government at the end of...more

Cadwalader, Wickersham & Taft LLP

Haworth: Residency Tie-Breaker Tests in a ‘Round the World’ Tax Scheme

The UK’s First-tier Tribunal recently considered the application of the “place of effective management” residency tie-breaker test found in double tax treaties in the recent case of Haworth and others v HMRC [2022] UKFTT 34...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

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

Jones Day on

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

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