News & Analysis as of

Cross-Border Transactions HMRC

Pillsbury - Propel

ASAs vs. SAFEs vs. Convertible Loan Notes: A Primer for Founders and Investors

Pillsbury - Propel on

Startups continue to have an increasingly international presence (or, at the very least, an international plan), and investors continue to scour the globe for investment opportunities. ...more

Proskauer - Tax Talks

Narrowing of UK intermediaries’ DAC 6 reporting requirements

Proskauer - Tax Talks on

On 30 December, the UK government laid regulations that will significantly reduce the type of cross-border arrangement that will need to be reported by UK intermediaries under the so-called DAC 6 rules on 31 January 2021 and...more

Proskauer Rose LLP

UK Tax Round Up - June 2020

Proskauer Rose LLP on

UK COVID-19 Developments - HMRC updates its trading activities guidance - HMRC has updated its guidance at BIM48000 regarding how legislation and case law should be applied where a business makes changes to its...more

White & Case LLP

DAC6 reporting delay proposed by EU Commission due to COVID-19

White & Case LLP on

DAC6 summary - Council Directive 2018/822 – known as DAC6 – is the sixth amendment to the EU Directive on Administrative Cooperation 2011/16/EU. DAC6 is aimed at providing the tax authorities with a “warning system” in...more

McDermott Will & Schulte

How CCO Reasonable Prevention Procedures Can Help You Mitigate DAC6 Penalties

Corporate criminal offences (CCOs) under Part 3 Criminal Finances Act 2017 (CFA) are increasingly coming under the spotlight of the UK tax authorities. In a 10 February 2020 press release published in response to a Freedom of...more

Katten Muchin Rosenman LLP

UK Regulations Implementing EU Tax Anti-Avoidance Disclosure Laws Finalised

KEY POINTS - The UK Regulations, finalised on 13 January 2020, will only apply in relation to direct EU taxes. - The Legal Professional Privilege exemption is still unclear. - Penalties have been capped at £5,000. ...more

Katten Muchin Rosenman LLP

New EU-Wide Tax Anti-Avoidance Law Introduces Sweeping Disclosure Requirements

Key Points - Coming into force on 1 July 2020, EU DAC6 Regulations will require intermediaries in certain cross-border arrangements to disclose activity to tax authorities. - The DAC will apply retroactively to affected...more

Proskauer Rose LLP

UK Tax Round Up - August 2019

Proskauer Rose LLP on

UK Case Law Developments - Valid notice crucial to tax indemnity claim - The Court of Appeal (CA) decision in Stobart Group Ltd v Stobart and another is a cautionary tale for any purchaser who, following the...more

Womble Bond Dickinson

The EU’s Contingency Plans for Customs & the Export of Goods in a “No Deal” Brexit

Womble Bond Dickinson on

The European Commission has published its Contingency Action Plan for a “No Deal” Brexit. The contingency plan seeks to mitigate significant adverse effects, but the Commission's paper emphasizes...more

Pillsbury Winthrop Shaw Pittman LLP

EU: “Hard” Brexit Would Come with Border Friction and Costs

The European Union has published a technical note warning of dire consequences for businesses if the UK leaves the EU with no deal in place. The European Commission has warned companies across Europe to prepare for...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Delaware LLCs and UK Entity Classification: The Fallout From the Curious Case of George Anson"

Fundamental to any developed tax policy is knowing who the taxpayer is (or should be) with respect to any particular transaction. Although that can be relatively straightforward in purely domestic situations, a cross-border...more

11 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide