UK corporate offence of failure to prevent tax evasion
Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more
Two Birds, One Stone: Addressing COO and DAC6 Risks in Tandem - UK Criminal Finances Act 2017 (CFA) and the EU Directive on Administrative Cooperation (DAC6) compliance matters are likely to come under increased scrutiny...more
In light of COVID-19, and in response to requests from European trade associations, the European Commission has published its proposal to amend Directive 2011/16/EU which deals with various strands of administrative...more
On 13 March 2019 the UK government published details of the temporary rates of customs duty it would impose on imports should a "no deal" Brexit occur. Under the temporary regime, the government expects 87% of total imports...more
UK Developments - Taxpayer succeeds in judicial review case against HMRC - On 22 November 2018, the Upper Tribunal published its decision on the judicial review case of R. (on the application of Vacation Rentals (UK)...more
VAT treatment of supplies of non-employed temps clarified - A recent Court of Appeal case – Adecco v HMRC – clarifies a longstanding question over seemingly contradictory case law on the VAT treatment of employment agency...more
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
Welcome to the March edition of the Proskauer UK Tax Round Up. As promised, the Spring Statement from the Chancellor focused on the economy and public finances without any major tax announcements. However, a few interesting...more
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
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
On July 8, the Right Honourable George Osborne MP, Chancellor of the Exchequer, introduced measures in his Summer Budget to abolish what is commonly known as the “base cost shift” as applied to sums received by individuals...more