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Appeals › United Kingdom › Double Taxation

Cadwalader, Wickersham & Taft LLP

What Constitutes a POEM?

Cadwalader, Wickersham & Taft LLP on

In Haworth v HMRC [2025] EWCA Civ 822 (Haworth) the UK Court of Appeal (CoA) provided much needed clarity regarding the approach to determining the ‘place of effective management’ (POEM) in the context of the UK’s double tax...more

Proskauer Rose LLP

UK Tax Round Up - December 2023

Proskauer Rose LLP on

Welcome to December’s edition of our UK Tax Round Up. This month has seen two interesting decisions on the connections needed for amounts to be taxed as employment income, the latest instalment in the BlueCrest partner...more

Troutman Pepper Locke

UK Supreme Court Decision in Anson v. HMRC Reverses Established Tax Treatment of US LLCs

Troutman Pepper Locke on

In its July 1, 2015 decision in the case of Anson v. HM Revenue & Customs (2015 UKSC 44), the Supreme Court of England and Wales ruled that a Delaware limited liability company was “transparent” for UK income tax purposes. A...more

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