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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

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

Cadwalader, Wickersham & Taft LLP

Perfect Influence?

In HMRC v BlueCrest Capital Management (UK) LLP [2023] UKUT 00232 (TCC) (“HMRC v BlueCrest”), the Upper Tribunal (“UT”) has upheld the decision of the First-tier Tribunal (“FTT”) regarding the United Kingdom (“UK”) salaried...more

Cadwalader, Wickersham & Taft LLP

Good v HMRC – What Does ‘Entitled To’ Mean?

The Court of Appeal in Good v HMRC [2023] EWCA Civ 114 upheld the decision of the Upper Tribunal in examining the meaning of “entitled to” in the context of Section 611 of the Income Tax (Trading and Other Income) Act 2005...more

Hogan Lovells

How the UK Trust Registration Service applies to trusts of real estate and changes for unit trusts

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Trustees which are UK resident, have UK assets or income which trigger a UK tax liability or directly acquire UK land on or after 6 October 2020 will generally have to register the trust with HMRC's Trust Registration Service...more

Dechert LLP

Learnings from Bluecrest – Investment Management LLPs and the Salaried Member Rules

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The First Tier Tax Tribunal on 29 June, 2022, issued its judgment in Bluecrest, the first case considering the application of the salaried member legislation to members of a hedge fund management LLP. The judgment will be of...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

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 - August 2021

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In Claims Advisory Group v HMRC, The Upper Tribunal (UT) has confirmed that the service of claiming compensation on behalf of third parties for mis-sold payment protection insurance (PPI), is subject to VAT and not exempt...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

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

Dechert LLP

COVID-19: UK Tax Residence Risks for Offshore Funds and Related Entities – HMRC Update

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Following on from our recent OnPoint (COVID-19: UK Tax Residence Risks for Offshore Funds and Related Entities), HMRC has now published guidance on the corporate residence issues posed by COVID-19. ...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

Proskauer Rose LLP

UK Tax Round Up - August 2019

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UK Case Law Developments - Valid notice crucial to tax indemnity claim - The Court of Appeal (CA) decision in Stobart Group Ltd v Stobart and another is a cautionary tale for any purchaser who, following the...more

Proskauer Rose LLP

UK Tax Round Up - October 2018

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General UK Tax Developments - CIOT responds to the draft profit fragmentation provisions in the Finance Bill 2019 - The Chartered Institute of Taxation (CIOT) has published its response to the profit fragmentation...more

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