The UK Budget took place on 29th October. The Chancellor, Philip Hammond, took the opportunity to make a series of targeted changes to the UK’s tax system, some of which had already been announced, but several of which were...more
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
10/30/2018
/ Acquisitions ,
BEPS ,
Court of Justice of the European Union (CJEU) ,
EU ,
HMRC ,
International Tax Issues ,
Mergers ,
OECD ,
Shareholders ,
Stamp Duty Land Tax ,
Tax Liability ,
UK ,
UK Brexit ,
Value-Added Tax (VAT)
UK Case Law Developments -
Entrepreneurs' relief – voting rights not imputed for equitable reasons -
In George v HMRC, the First Tier Tribunal (FTT) decided that they could not apply the equitable principle that...more
10/8/2018
/ BEPS ,
Corporate Taxes ,
EU ,
European Commission ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Ireland ,
Share Purchase Agreements ,
Tax Planning ,
Tax Tribunal ,
UK ,
Value-Added Tax (VAT)
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)
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by the Organisation for Economic Co-operation and Development (“OECD”) on...more