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United Kingdom International Tax Issues Income Taxes

Dechert LLP

Labour Budget 2024: Reforms to the Taxation of Carried Interest

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The Chancellor of the Exchequer, Rachel Reeves MP, presented her first Budget to Parliament on 30 October 2024. In it, she announced both tax rate increases and also proposals which would fundamentally change the tax...more

Cadwalader, Wickersham & Taft LLP

GE Financial Investments: What Determines Residency?

Background - In GE Financial Investments Limited the Court of Appeal (“CoA”) overturned the Upper Tribunal’s (“UT”) decision and held that double taxation relief was not available under the UK-US double tax treaty (the...more

Cadwalader, Wickersham & Taft LLP

“Ephemeral” Payments and Beneficial Entitlement

Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises.  The decision of the UK’s Court of Appeal in Hargreaves Property Holdings Limited [2024] EWCA Civ 365,...more

McDermott Will & Emery

UK Labour Party's Statement on Non-Dom Tax Reforms

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Following the UK Government’s 6 March announcement of tax reforms for the current “non-dom” tax regimes, the opposition Labour party has begun to outline how its plans would differ if they win the next UK general election. In...more

Cadwalader, Wickersham & Taft LLP

Pin-pointing Residence

The identification of where a company is resident is a critical element in accessing the benefits of a double tax treaty. GE Financial Investments Limited (“GEFI Limited”) was a UK incorporated and tax resident company...more

Littler

A Deep Dive into Recent Pension Tax Changes in the UK

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In March, the UK government announced changes to the tax regime surrounding pensions as part of the annual Budget. In this piece, we take a deep dive into what these changes are, who they affect, what employers should be...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

UK: HMRC changes to notification process for opting to tax on land and buildings

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Whilst the default position is that supplies of land and buildings are usually exempt from VAT (the sale of new commercial buildings excepted), landowners of commercial property will often choose to opt to tax their property...more

Akin Gump Strauss Hauer & Feld LLP

UK Mini-Budget - Helpful for Asset Managers

The government’s 2022 Growth Plan, deceptively referred to as the “mini-budget,” has brought in notable changes likely to impact the funds industry. In particular, a number of the changes will help ensure the continued...more

Orrick, Herrington & Sutcliffe LLP

UK Growth Plan ('Mini-Budget') 2022

On 23 September 2022, the UK Government announced a number of significant tax changes in its Growth Plan (widely referred to in the media as a ‘Mini-Budget’). Here are ten key takeaways, of particular relevance to our...more

Cadwalader, Wickersham & Taft LLP

UK Government Considers Changes to the Rules on Sovereign Immunity from Direct Taxation

The UK Government has recently consulted on a revised approach to sovereign immunity from direct taxation. The consultation was brought about owing to the view that whilst the scope of sovereign immunity-based exemptions has...more

Cadwalader, Wickersham & Taft LLP

BlueCrest Salaried Members Case: Who Is a Significant Influencer?

BlueCrest Capital Management (UK) LLP v HMRC [2022] UKFTT 204 (TC) is the first case considering the UK salaried members rules under ss 863A – 836G Income Tax (Trading and Other Income) Act 2005 (the “Salaried Members...more

Proskauer Rose LLP

UK Tax Round Up - May 2022

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Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

McDermott Will & Emery

International News: Spotlight on Tax

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more

Proskauer Rose LLP

UK Tax Round Up - February 2022

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Welcome to February’s edition of our UK Tax Round Up. This month’s edition includes updated guidance on the VAT treatment of contractual termination payments, updated HMRC guidance on the assessment of “substantial”...more

Proskauer Rose LLP

UK Tax Round Up - January 2022

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UK Case Law Developments - Contributions to remuneration trust scheme not tax deductible - In Strategic Branding Ltd v HMRC, the First-tier Tribunal (FTT) held that sums contributed by the taxpayer company to a...more

Proskauer Rose LLP

UK Tax Round Up - November 2021

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Welcome to November’s edition of the UK Tax Round Up. This month has seen publication of the Finance Bill 2021-22 (what will become the Finance Act 2022) including draft legislation for the basis period reform, UK asset...more

Proskauer Rose LLP

UK Tax Round Up - September 2021

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In Fashion on the Block Limited v HMRC, the First-tier Tribunal (FTT) has allowed the taxpayer’s appeal against HMRC’s decision not to allow the taxpayer company to issue seed enterprise investment scheme (SEIS) certificates...more

Eversheds Sutherland (US) LLP

Partial Brexit? For income tax treaty purposes, US and UK competent authorities vote to remain 

While the United Kingdom left the European Union (EU) last year, the competent authorities of United States and United Kingdom have agreed that the United Kingdom will remain in the EU for purposes of the US-UK Income Tax...more

Proskauer Rose LLP

UK Tax Round Up - July 2021

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In Haworth v HMRC the Supreme Court (SC) upheld the Court of Appeal’s (CA’s) decision to quash a follower notice (FN) and accelerated payment notice (APN) issued to the taxpayer, Mr Haworth. An FN can be issued by HMRC where...more

Proskauer Rose LLP

UK Tax Round Up - June 2021

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UK Case Law Developments - Income tax consequences of pension-related payments in E.ON v HMRC - E.ON v HMRC concerned a large UK power and gas supplier, which paid certain lump sum payments, called “facilitation...more

Proskauer Rose LLP

UK Tax Round Up - March 2021

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Spring Budget and Tax Day - After months of speculation about the possibility that capital gains tax (CGT) rates would be increased in the Spring Budget, both it and the government’s follow up “Tax Day” on 23 March passed...more

Proskauer Rose LLP

UK Tax Round Up - February 2021

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UK Case Law Developments - EIS relief not available for shares carrying preferential rights - The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more

Akin Gump Strauss Hauer & Feld LLP

Budget 2021: Tax, But Only Half the Story

On March 3, 2021, the U.K. government announced its 2021 Spring Budget (the “Budget”) which contained a number of extensions to measures designed to support the country even after our expected emergence from lockdown. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Employment Flash - February 2021

In this issue of UK Employment Flash, we examine the latest employment law developments, news and insights from the UK, including considerations for employers requiring staff to get the COVID-19 vaccine, the delayed rollout...more

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