GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion
Welcome to July’s edition of our UK Tax Round Up. Apart from the draft legislation and accompanying material released on 21 July as part of “L-Day” (legislation day), July was a fairly quiet month for UK tax developments....more
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
Cada año, el Servicio de Impuestos Internos (SII) actualiza la guía denominada Catálogo de Esquemas Tributarios, que contiene un listado de operaciones que pueden ser declaradas elusivas por aplicación de la Norma General...more
Companies must approach HMRC with suitable care when proposing a restructuring plan, mindful of lessons learned from recent case law. Ever since unpaid taxes due to HMRC were “crammed down” pursuant to a restructuring plan...more
A recent decision has helped to frame the tests articulated by the Supreme Court in Sequana. The Supreme Court’s landmark decision in Sequana[2022] UKSC 25.leaves many unanswered questions, and finding a common thread...more
The Spanish interest limitation rule establishes that net financial expenses are deductible for Spanish Corporate Income Tax ("CIT”) purposes with the annual limit of the higher of (i) 30% of the Tax EBITDA (as defined in the...more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Autumn Budget for 2021 on 27 October 2021. The Budget was delivered against the backdrop of the UK’s ongoing recovery from the Covid‑19 pandemic and the...more
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
Tax avoidance is the process of manipulating tax rules to reduce the amount of tax payable and obtaining a financial advantage that was never the intention of the legislation. A typical example of tax avoidance involves the...more
Spring Budget and Tax Day - After months of speculation about the possibility that capital gains tax (CGT) rates would be increased in the Spring Budget, both it and the government’s follow up “Tax Day” on 23 March passed...more
UK Case Law Developments - EIS relief not available for shares carrying preferential rights - The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more
With effect from December 1, 2020, Her Majesty's Revenue and Customs ("HMRC") ranks ahead of floating charge holders and unsecured creditors with respect to recovering certain pre-insolvency taxes from an insolvent business...more
UK COVID-19 Developments - Extension of support for employed and self-employed workers - On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more
UK General Tax Developments - HMRC updates guidance on what constitutes "ordinary share capital" - Following the decision by the First-tier Tribunal (FTT) in Warshaw V HMRC, reported in our UK tax blog earlier this...more
The Commonwealth Senate Economics Committee (a standing committee composed by members of the upper house of Parliament) handed down its long-awaited final report on corporate tax avoidance in Australia. The final report is...more
On April 2, in quick succession, the IRS and Treasury announced notices addressing two provisions added by the Tax Cuts and Jobs Act (TCJA): the repatriation tax under Section 965 and withholding on non-publicly traded...more
As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more
The Chancellor of the Exchequer delivered the UK Budget for 2017 on 22 November 2017. Delivered against the backdrop of the UK’s ongoing negotiations to exit from the European Union, the Budget featured a significant...more
The Chancellor of the Exchequer delivered the UK Budget for 2016 on 16 March 2016. The Budget was delivered against the backdrop of international tax developments, relating to the Organisation for Economic Co-operation and...more