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Double Taxation International Tax Issues HMRC

Cadwalader, Wickersham & Taft LLP

What Constitutes a POEM?

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

Cadwalader, Wickersham & Taft LLP

Burlington: Good News for the Secondary Debt Market

In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) (“Burlington”) the Upper Tribunal (“UT”) dismissed HMRC’s appeal, holding that the First-tier Tribunal (“FTT”) was right to conclude that the anti-abuse provision...more

Cadwalader, Wickersham & Taft LLP

Haworth: Residency Tie-Breaker Tests in a ‘Round the World’ Tax Scheme

The UK’s First-tier Tribunal recently considered the application of the “place of effective management” residency tie-breaker test found in double tax treaties in the recent case of Haworth and others v HMRC [2022] UKFTT 34...more

Proskauer Rose LLP

UK Tax Round Up - June 2021

Proskauer Rose LLP on

UK Case Law Developments - Income tax consequences of pension-related payments in E.ON v HMRC - E.ON v HMRC concerned a large UK power and gas supplier, which paid certain lump sum payments, called “facilitation...more

Proskauer Rose LLP

UK Tax Round Up - May 2021

Proskauer Rose LLP on

UK General Tax Developments - Stamp Duty and COVID-19 - Since the start of the first UK lockdown in March 2020, HMRC has been accepting that documents can be stamped electronically. HMRC has now confirmed that, where...more

Freeman Law

International Tax Treaty: The United Kingdom

Freeman Law on

Quick Summary. In the United Kingdom, Her Majesty’s Revenue and Customs (HMRC) is responsible for administering and collecting taxes in the UK. For 2019, HMRC collected $841.19 billion in tax revenue. But it took over 300...more

Jones Day

The UK’s Digital Services Tax: Where Are We Now?

Jones Day on

Current Status: The UK Government is moving ahead with its implementation of the Digital Services Tax ("DST") despite concerns raised by the United States and the Organisation of Economic Co-operation and Development ("OECD")...more

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