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Foreign Corporations HMRC Tax Planning

Cadwalader, Wickersham & Taft LLP

Beard v HMRC: Capital Dividends. A Triumph of Form Over Substance?

Introduction The recent UK Court of Appeal decision in Beard considered the treatment of dividends from a non-UK company, particularly the interpretation of ‘dividends of a capital nature’. In her leading judgment, Falk LJ...more

Cadwalader, Wickersham & Taft LLP

Not Yet Fixed in Place

In Barclays Service Corporation and another v HMRC, the First Tier Tribunal (the “FTT”) has held that the UK branch of an overseas company did not qualify as a member of a value added tax (“VAT”) group in the UK....more

Proskauer Rose LLP

UK Tax Round Up - April 2018

Proskauer Rose LLP on

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

Proskauer Rose LLP

UK Tax Round Up - February 2018

Proskauer Rose LLP on

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

Bilzin Sumberg

Change in the UK Treatment of Dual-Resident Companies May Affect U.S. Tax Planning

Bilzin Sumberg on

On November 30, 2015, the UK tax authorities at HM Revenue and Customs (HMRC) reached an agreement with Jersey about the interpretation of the company residence tie-breaker provision of the Jersey-UK income tax treaty. After...more

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