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United Kingdom Tax Planning Corporate Taxes

Cadwalader, Wickersham & Taft LLP

The UK Government’s Autumn Budget 2024

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2024 on 30 October 2024. The Budget was the first to be delivered by the new Chancellor of the Exchequer, following the election of the Labour...more

Cadwalader, Wickersham & Taft LLP

Not Yet Fixed in Place

In Barclays Service Corporation and another v HMRC, the First Tier Tribunal (the “FTT”) has held that the UK branch of an overseas company did not qualify as a member of a value added tax (“VAT”) group in the UK....more

Cadwalader, Wickersham & Taft LLP

Recognising “Imported Losses” Under the UK’s Loan Relationship Rules

The United Kingdom (“UK”) has specific corporate tax rules on the taxation of loan relationships (parts 5 and 6 of the Corporation Tax Act 2009 (the “Loan Relationships Regime”)). The Loan Relationships Regime contains rules...more

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

Walkers

Guernsey and Jersey re-affirm commitment to OECD Pillar Two implementation

Walkers on

The Crown Dependencies have re-affirmed their commitment to international tax standards and the continued value of inter-island cooperation in areas of mutual interest in international tax policy. Ministers from...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

Wilson Sonsini Goodrich & Rosati

FAQs: UK Employee Equity Incentive Annual Reporting Deadline Approaching - 2022/2023 Annual Returns Must Be Filed by July 6, 2023

Companies operating employee equity incentive arrangements in the United Kingdom, including companies incorporated or registered outside of the United Kingdom, are mandated to file an online annual return with HM Revenue &...more

Akin Gump Strauss Hauer & Feld LLP

UK Spring Budget 2023: Points for Asset Managers

Introduction - On 15 March 2023, the UK government revealed the widely anticipated Spring Budget, which contained a number of measures that may be of interest to asset managers....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

Cadwalader, Wickersham & Taft LLP

UK VAT Treatment of Fund Management Review Announced

As part of the Edinburgh Reforms announced by the UK Government (link back to “UK FS Reforms”), the UK Government has launched a public consultation on the VAT treatment of fund management. The consultation, published on 9...more

A&O Shearman

Volatile Reaction to UK “Mini-Budget”

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Bank of England market intervention after presentation of tax package - On 23 September, the new U.K. Government conducted the emergency fiscal event it had scheduled when taking power at the beginning of the month. Many...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

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

Orrick, Herrington & Sutcliffe LLP

The UK Qualifying Asset Holding Company Regime - Highlights

The United Kingdom ("UK") Qualifying Asset Holding Company ("QAHC") regime (at Schedule 2 to Finance Act 2022) comes into force on 1 April 2022. The HM Revenue & Customs ("HMRC") policy paper dated 27 October 2021 states:...more

Katten Muchin Rosenman LLP

Winners and Losers: HMRC Revises Policy on VAT Treatment of Fees and Compensation for Early Termination of Contracts

HM Revenue and Customs (HMRC) now considers that charges made by businesses to their customers to withdraw early from agreements to supply goods or services are payments for a supply and potentially subject to value added-tax...more

Katten Muchin Rosenman LLP

Katten Corporate and Real Estate Tax Case Roundup – February 2022

In this roundup, we look at some of the key cases in corporate and real estate tax from December 2021 to January 2022, including the value–added tax (VAT) decisions on input VAT that was not passed on to final consumers and...more

A&O Shearman

Government Releases Final Tax Regulations on the Transition from Interbank Offered Rates

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On December 30, 2021, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (IRS) released a pre-publication version of final regulations (Treas. Reg. § 1.1001-6) addressing the principal tax...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

Dechert LLP

Notification of Uncertain Tax Treatment by Large Businesses in the UK

Dechert LLP on

On 20 July 2021 (or so-called “Legislation Day 2021”), amongst a raft of other items, the UK government published its response to its second consultation on proposals for a new legislative regime that will require large...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

Proskauer Rose LLP

UK Tax Round Up - April 2021

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UK Case Law Developments - Tax avoidance motive did not prevent availability of share for share exchange treatment - In Euromoney Institutional Investor plc v HMRC, the FTT held that the share for share exchange...more

Proskauer Rose LLP

UK Tax Round Up - March 2021

Proskauer Rose LLP on

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

Cadwalader, Wickersham & Taft LLP

UK Proposes Securitization Tax Reform

On March 23, 2021, the UK Government announced a public consultation focused on the clarification and reform of the UK’s tax regime for securitization companies....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

Proskauer Rose LLP

UK Tax Round Up - December 2020

Proskauer Rose LLP on

COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more

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