VAT treatment of supplies of non-employed temps clarified -
A recent Court of Appeal case – Adecco v HMRC – clarifies a longstanding question over seemingly contradictory case law on the VAT treatment of employment agency...more
8/29/2018
/ Board of Directors ,
Capital Expenditures ,
Corporate Taxes ,
Cross-Border ,
EU ,
Foreign Corporations ,
HMRC ,
Holding Companies ,
International Tax Issues ,
Regulatory Oversight ,
UK ,
Value-Added Tax (VAT)
General UK Tax Developments -
Enterprise management incentive (EMI) options State Aid approval -
We referred in the April UK Tax Round Up to the expiry of the EU's State Aid approval for EMI options. Fortunately, this...more
5/31/2018
/ Acquisitions ,
Anti-Avoidance ,
BEPS ,
Capital Losses ,
Corporate Taxes ,
EU ,
European Commission ,
Foreign Subsidiaries ,
HMRC ,
International Tax Issues ,
Mergers ,
UK ,
Value-Added Tax (VAT)
General UK tax developments -
Changes to taxation of termination payments -
HMRC has updated its Employment Income Manual to reflect the changes to the taxation of termination payments (including payments in lieu of...more
5/1/2018
/ Anti-Avoidance ,
Corporate Taxes ,
Cross-Border ,
EU ,
European Court of Justice (ECJ) ,
Foreign Acquisitions ,
Foreign Corporations ,
GAAR ,
Guidance Update ,
HMRC ,
Income Taxes ,
International Tax Issues ,
PILONs ,
Tax Planning ,
Tax Warrants ,
UK ,
Value-Added Tax (VAT)
Welcome to the March edition of the Proskauer UK Tax Round Up. As promised, the Spring Statement from the Chancellor focused on the economy and public finances without any major tax announcements. However, a few interesting...more
4/5/2018
/ Anti-Avoidance ,
Capital Gains ,
Controlling Person ,
Corporate Taxes ,
Court of Justice of the European Union (CJEU) ,
Cross-Border ,
Entrepreneurs ,
EU ,
European Commission ,
Federal Budget ,
Foreign Investment ,
GAAR ,
HMRC ,
International Tax Issues ,
Investment Management ,
Limited Partnerships ,
Remuneration ,
Tax Credits ,
Tax Rates ,
UK
Case law developments -
Settlement payment not deductible as an expense of a trade (Vaines v HMRC) -
Mr. Vaines was a solicitor. In the 2007/08 tax year he paid a settlement amount to a third party that had made a...more
2/23/2018
/ Corporate Taxes ,
Cross-Border ,
EU ,
European Court of Justice (ECJ) ,
Foreign Acquisitions ,
Foreign Corporations ,
Guidance Update ,
HMRC ,
Income Taxes ,
International Tax Issues ,
PILONs ,
Tax Planning ,
Tax Warrants ,
UK ,
Value-Added Tax (VAT)
The impact of discounts on consideration for VAT purposes (Finanzamt Bingen-Alzey v Boehringer Ingelheim Pharma GmbH & Co. KG) -
The ECJ has confirmed that consideration for VAT purposes should be reduced by any discount...more
1/29/2018
/ Corporate Bonds ,
Corporate Taxes ,
EU ,
European Commission ,
European Court of Justice (ECJ) ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Share Purchase Agreements ,
Tax Planning ,
Tax Tribunal ,
Tax Warrants ,
UK ,
Value-Added Tax (VAT)
Finance (No. 2) Bill 2017-19 -
The first version of the Finance (No. 2) Bill 2017-19 was published on 1 December 2017. The majority of the Bill's content had been previously announced at the Autumn 2017 Budget (see...more
12/29/2017
/ BEPS ,
Common Reporting Standard (CRS) ,
Corporate Taxes ,
Disclosure Requirements ,
Distribution Rules ,
EU ,
HMRC ,
International Tax Issues ,
Member State ,
OECD ,
Royalties ,
Self-Employment Tax ,
Social Insurance Contributions ,
UK ,
Value-Added Tax (VAT)
UK Tax News and Developments -
The OTS publishes its report "Value added tax: routes to simplification" -
On 7 November, the Office of Tax Simplification (OTS) published its first report on VAT, which included a range...more
11/30/2017
/ CFC ,
Corporate Taxes ,
Court of Justice of the European Union (CJEU) ,
Diverted Profits Tax ,
Draft Guidance ,
EU ,
European Commission ,
HMRC ,
Income Taxes ,
International Tax Issues ,
National Insurance Contributions ,
OTS ,
Remuneration ,
Restitution ,
Self-Employment Tax ,
Tax Reform ,
Threshold Requirements ,
UK ,
Value-Added Tax (VAT)
UK Tax News and Developments -
Government White Paper on Customs Bill -
On 9 October, the Government published a White Paper setting out its approach to the introduction of a new customs and VAT regime after the UK...more
10/30/2017
/ Amazon ,
BEPS ,
Corporate Taxes ,
Double Taxation ,
EU ,
European Court of Justice (ECJ) ,
HMRC ,
Ireland ,
Island of Guernsey ,
Luxembourg ,
OECD ,
OTS ,
PACs ,
Pension Funds ,
Remuneration ,
Retirement Plan ,
SIFIs ,
State Aid ,
Tax Avoidance ,
Tax Tribunal ,
UK ,
UK Brexit ,
Value-Added Tax (VAT) ,
Withholding Tax
International Tax Developments -
BEPS Multilateral Convention signed -
On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more
6/16/2017
/ Anti-Avoidance ,
BEPS ,
Capital Gains ,
Corporate Bonds ,
Corporate Taxes ,
Double Taxation ,
EU ,
Film Tax Credits ,
HMRC ,
Investment Funds ,
OECD ,
Tax Deductions ,
UK ,
Value-Added Tax (VAT)
The United Kingdom (UK) has voted to leave the European Union (EU). Although the vote will have long term implications, in the short term there will be no change to the current legal and regulatory status quo; the UK will...more
6/27/2016
/ Alternative Investment Fund Managers Directive (AIFMD) ,
Antitrust Provisions ,
David Cameron ,
EU ,
EU Passport ,
Financial Services Industry ,
Insolvency ,
Member State ,
Mergers ,
MiFID ,
One-Stop Shop ,
Popular ,
Referendums ,
Resignation ,
UK ,
UK Brexit
We wrote in February (European Commission Publishes Anti Tax Avoidance Package) about the draft EU Anti Tax Avoidance Directive (“ATAD”).
On 21st June 2016, the EU Council agreed on the final text of the ATAD and it will...more
6/24/2016
/ Anti-Avoidance ,
BEPS ,
Controlled Foreign Corporations ,
EU ,
EU Council of Ministers ,
Foreign Subsidiaries ,
Member State ,
OECD ,
Tax Avoidance ,
Tax Deductions ,
Tax Exemptions
Country-by-country reporting (“CBCR”) is one of the OECD BEPS deliverables (under Action 13). It is expected to be a significant tool used by tax authorities’ auditors in evaluating a multinational group’s transfer pricing...more
On 28 January 2016, the European Commission published a draft Anti Tax Avoidance Package in order to ensure increased tax transparency and effective taxation within, and outside of, the EU. The package includes a proposed...more
Proskauer has released the 2015 Proskauer Annual Review and Outlook for Hedge, Private Equity and Other Private Funds. The 88-page report is a summary of significant legal changes and developments in the private funds space...more
11/25/2015
/ China ,
Cybersecurity ,
EU ,
Gift Tax ,
Hedge Funds ,
Hong Kong ,
Internships ,
Popular ,
Private Equity ,
Private Funds ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
UK ,
Volcker Rule ,
Whistleblowers