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Draft Guidance ,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 UK Government has announced in today’s Budget (22 November) that it is launching a consultation on extending the scope of UK tax on real estate.
Currently, non-UK residents who are investors in UK land and buildings...more
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
UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...more
9/22/2017
/ Corporate Taxes ,
Criminal Fascilitation ,
Debt Trading ,
Foreign Corporations ,
HMRC ,
OECD ,
OTS ,
Partnerships ,
Remuneration ,
SIFs ,
Stamp Taxes ,
Tax Avoidance ,
Tax Evasion ,
Tax Reform ,
Tax Tribunal ,
Transfer Pricing ,
UK ,
Value-Added Tax (VAT) ,
Withholding Tax
The Upper Tribunal (Tax and Chancery Chamber), the UK’s second level tax appeal court, have just published their judgement in the McQuillan case, which considered whether shares with no right to dividends or any other profits...more
As mentioned in our July 2017 edition of UK Tax Round Up, the UK has enacted a new corporate criminal offence of failing to prevent the facilitation of tax evasion. The law comes into effect on 30th September 2017, and...more
UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more
8/25/2017
/ Appeals ,
BEPS ,
Capital Gains ,
Corporate Taxes ,
EBITDA ,
GAAR ,
HMRC ,
Interest Income ,
Investment Funds ,
OECD ,
Tax Deductions ,
Tax Tribunal ,
UK ,
UK Brexit
UK Tax News and Developments -
Conservative legislative agenda set out in Queen's Speech -
Following the UK general election on 8 June 2017, at which the Conservative party won the largest number of seats but lost its...more
7/21/2017
/ BEPS ,
Corporate Governance ,
Corporate Taxes ,
Distribution Rules ,
Gaming ,
HMRC ,
OECD ,
Self-Employment Tax ,
Social Insurance Contributions ,
Stamp Taxes ,
Tax Avoidance ,
Tax Evasion ,
UK ,
Value-Added Tax (VAT)
Following the UK general election on 8 June 2017, at which Theresa May’s Conservative party won the largest number of seats but lost its overall majority, the Queen’s Speech setting out the now minority Conservative...more
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)
Budget and Finance Bill -
General Election – Finance Bill (No.2) 2017 Curtailed -
The Finance (No.2) Bill received Royal Assent on 27 April 2017, becoming the Finance Act 2017. However, as a result of Theresa May...more
5/17/2017
/ Borrowers ,
Criminal Finances Bill ,
Double Taxation ,
Financial Reporting ,
HMRC ,
Holding Companies ,
Legislative Agendas ,
Passporting ,
Sovereign Wealth Funds ,
UK ,
UK Parliament ,
Value-Added Tax (VAT)
Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more
4/7/2017
/ Asset Management ,
Budgets ,
Carry Forward ,
Corporate Taxes ,
Double Taxation ,
EBITDA ,
Employee Stock Purchase Plans ,
Foreign Corporations ,
HMRC ,
Holding Companies ,
Interest Payments ,
LLPs ,
New Legislation ,
Non-Resident Income Taxes ,
Offshore Funds ,
Partnerships ,
Passporting ,
Publicly-Traded Companies ,
Remuneration ,
Shareholders ,
Tax Deductions ,
Tax Exemptions ,
Tax Treaty ,
UK ,
Value-Added Tax (VAT) ,
Withholding Tax
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
Many people will be familiar with the information gathering and reporting requirements the OECD’s Common Reporting Standard (“CRS”) places on financial institutions. The first exchanges of information between tax authorities...more
9/29/2016
/ Beneficial Owner ,
Capital Gains ,
Common Reporting Standard (CRS) ,
Financial Institutions ,
HMRC ,
Income Taxes ,
Inheritance Tax ,
OECD ,
Tax Evasion ,
Tax Penalties ,
UK
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
The UK’s 2016 budget was announced on Wednesday 16 March 2016. Although we are waiting for detailed legislation for most of the tax-related announcements, below is a brief summary of some tax points which have caught our...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
Further to our client alert in July this year, the UK Government recently proposed further changes to the UK taxation of carried interest and disguised investment management fees (DIMF).
The UK Government proposed...more
11/2/2015
/ Anti-Avoidance ,
Capital Gains ,
Capital Losses ,
Carried Interest Tax Rates ,
Federal Taxes ,
Fund Managers ,
Investment Adviser ,
Investment Management ,
Limited Partnerships ,
Management Fees ,
Pending Legislation ,
Proposed Amendments ,
Trustees ,
UK
On 8th July 2015, the UK Government announced several changes to UK tax legislation that will affect those holding carried interest in fund structures which utilise at least one partnership (including a limited partnership),...more
7/19/2015
/ Capital Gains ,
Carried Interest ,
Cost-Shifting ,
Foreign Investment ,
HMRC ,
Investment Management ,
Pay-for-Performance ,
Resident Non-Domiciled (RND) ,
Tax Deductions ,
Tax Reform ,
UK
Delaware LLC held to be UK tax transparent -
The UK Supreme Court has handed down its judgment on the final appeal in the Anson case, in which it treated a taxpayer's interest in a Delaware LLC as transparent for UK tax...more