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Withholding Tax United Kingdom International Tax Issues

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

Cadwalader, Wickersham & Taft LLP

Hargreaves Property: What Does the Latest Decision Mean for UK Withholding Tax?

In many respects, the Upper Tribunal’s decision in Hargreaves Property  will not have surprised tax practitioners as the decision reaffirms best practice considerations around a number of fundamental concepts in relation to...more

Cadwalader, Wickersham & Taft LLP

Hargreaves Property : What Does the Latest Decision Mean for UK Withholding Tax?

In many respects, the Upper Tribunal’s decision in Hargreaves Property will not have surprised tax practitioners as the decision reaffirms best practice considerations around a number of fundamental concepts in relation to UK...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 - November 2021

Proskauer Rose LLP on

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

A&O Shearman

Qualifying Asset Holding Companies (QAHCs): A new UK tax regime for alternative fund structures

A&O Shearman on

On 20 July 2021, the UK government published further details of, and draft legislation for, a new elective tax regime for alternative fund structures. Although certain aspects have yet to be clarified, the proposals have...more

Akin Gump Strauss Hauer & Feld LLP

New Obligations for Businesses Operating in the UK and Engaging UK “Consultants” from April 6, 2021

The United Kingdom (U.K.) currently operates certain off-payroll working rules (commonly referred to as IR35), which subject certain individuals (often operating as consultants to businesses) working through intermediaries...more

Cadwalader, Wickersham & Taft LLP

UK Asset Holding Companies: What Does the Future Hold?

The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021. The objectives of the UK Government in the consultation have been to improve...more

Freeman Law

International Tax Treaty: The United Kingdom

Freeman Law on

Quick Summary. In the United Kingdom, Her Majesty’s Revenue and Customs (HMRC) is responsible for administering and collecting taxes in the UK. For 2019, HMRC collected $841.19 billion in tax revenue. But it took over 300...more

McDermott Will & Emery

[Webinar] Virtual Tax Forum | Critical Tax Strategies for US MNCs with Operations in Germany, Italy, the UK and France - June 4th,...

Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more

Proskauer Rose LLP

UK Tax Round Up - March 2019

Proskauer Rose LLP on

EU developments - European Court rules that withholding tax exemptions under EU Directives can be denied by abuse of rights principle - At the end of February, the Court of Justice of the European Union (CJEU) issued...more

Morrison & Foerster LLP

Brexit: Tax Implications

The majority has spoken: on Friday 24 June, it was announced that the UK had voted to leave the European Union (the “EU”). The full implications of this decision are largely unknown, given that the UK is navigating...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Insights: Brexit"

On June 23, the UK electorate took the historic decision to leave the European Union, a process that has never been undertaken by any member state. While the vote itself does not trigger the process of exit from a legal...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2016 – Key Tax Measures

The Chancellor of the Exchequer delivered the UK Budget for 2016 on 16 March 2016. The Budget was delivered against the backdrop of international tax developments, relating to the Organisation for Economic Co-operation and...more

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