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Holding Companies Tax Planning International Tax Issues

Cadwalader, Wickersham & Taft LLP

Nordcurrent: Interpreting Anti-Abuse Rules

On 3 April 2025, in the case of Nordcurrent Group UAB (C-228/24) (“Nordcurrent”) the Court of Justice of the European Union (the “CJEU”) provided a preliminary ruling on the interpretation of the anti-abuse provisions in...more

Morrison & Foerster LLP

The UK’s New Asset Holding Company Tax Regime – Might You Be Enticed to Be Offshore No More?

Introduction The UK’s new Qualifying Asset Holding Company Regime (the “QAHC Regime”) comes into effect on 1 April 2022. The main objective of the regime is to make the UK a more desirable jurisdiction from which funds (which...more

Orrick, Herrington & Sutcliffe LLP

The UK Qualifying Asset Holding Company Regime - Highlights

The United Kingdom ("UK") Qualifying Asset Holding Company ("QAHC") regime (at Schedule 2 to Finance Act 2022) comes into force on 1 April 2022. The HM Revenue & Customs ("HMRC") policy paper dated 27 October 2021 states:...more

Proskauer Rose LLP

UK Tax Round Up - November 2021

Proskauer Rose LLP on

Welcome to November’s edition of the UK Tax Round Up. This month has seen publication of the Finance Bill 2021-22 (what will become the Finance Act 2022) including draft legislation for the basis period reform, UK asset...more

Cadwalader, Wickersham & Taft LLP

Closing the Books November 2021 - The UK's Autumn Budget 2021: Implications for Real Estate

As we draw close to the end of the year, we take a moment to revisit some of the taxation changes announced in the Autumn budget, with some of these being implemented in the upcoming tax year in April 2022. ...more

A&O Shearman

Qualifying Asset Holding Companies (QAHCs): A new UK tax regime for alternative fund structures

A&O Shearman on

On 20 July 2021, the UK government published further details of, and draft legislation for, a new elective tax regime for alternative fund structures. Although certain aspects have yet to be clarified, the proposals have...more

Cadwalader, Wickersham & Taft LLP

UK Asset Holding Companies: What Does the Future Hold?

The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021. The objectives of the UK Government in the consultation have been to improve...more

Proskauer Rose LLP

UK Tax Round Up - December 2020

Proskauer Rose LLP on

COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more

McDermott Will & Schulte

[Webinar] Virtual Tax Forum | Critical Tax Strategies for US MNCs with Operations in Germany, Italy, the UK and France - June 4th,...

Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more

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