News & Analysis as of

Tax Deductions United Kingdom

Hogan Lovells

Tax relief for predevelopment costs

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In a case that will be of interest to all developers and funders of UK infrastructure and energy projects, Orsted West of Duddon Sands v HMRC [2025] (previously known as Gunfleet Sands v HMRC), the Court of Appeal held that...more

IR Global

How donations to charity can provide tax relief

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Gift Aid transforms charitable donations by allowing charities and CASCs to claim 25p extra for every £1 given—at no additional cost to you. Higher and additional rate taxpayers can also claim valuable tax relief, making...more

Cadwalader, Wickersham & Taft LLP

Reap What You Sow – UK’s Unallowable Purpose Rule Considered Again

In Syngenta Holding Limited v HMRC [2024] UKFTT 998 (TC) (“Syngenta”), the UK’s First-tier Tribunal (“FTT”) denied a deduction for interest on an intra-group loan on the basis that the loan had an unallowable purpose for the...more

Proskauer Rose LLP

UK Tax Round Up - November 2024

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Welcome to the November 2024 edition of our UK Tax Round Up. This month has seen publication of the Finance Bill 2024-25 and interesting cases on the loan relationship unallowable purpose test and the extent that tax applies...more

Akin Gump Strauss Hauer & Feld LLP

Labouring Over the Loophole: The Labour Government’s Proposed Reform of Carried Interest Taxation

The Chancellor’s announcement on Wednesday that the UK’s capital gains tax (CGT) rate for carried interest would be increased by only a few percentage points from 28% to 32%, effective April 2025, was welcome news to many....more

BCLP

A Capital Blow for Deducting Management Expenses

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The Supreme Court confirmed in Centrica Overseas Holdings Ltd v HMRC that the tests for trading and management expenses of a capital nature are the same. The decision also confirms that once a company has decided in principle...more

Latham & Watkins LLP

Lexology In-Depth - Acquisition And Leveraged Finance

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It was a muted start to the year for the acquisition and leveraged finance market due to a challenging macroeconomic climate. Interest rate hikes at one of the fastest paces on record, surging inflation (particularly in...more

Cadwalader, Wickersham & Taft LLP

Examining "Purpose"

The recent Upper Tribunal (“UT”) decision in JTI Acquisitions Company (2011) Ltd v HMRC [2023] UKUT 194 (TCC) has further illuminated the interpretation and application of the “unallowable purposes” rule in the UK’s loan...more

Proskauer Rose LLP

UK Tax Round Up - September 2023

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Welcome to the September edition of the UK Tax Round Up. This month has seen interesting decisions on the salaried members rules, the scope of arrangements for the CGT rollover main tax avoidance purpose test and the...more

Proskauer Rose LLP

UK Tax Round Up - July 2023

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Welcome to July’s edition of our UK Tax Round Up. This month has seen a number of interesting tribunal decisions, including the denial of double tax relief and of employee expense deductions and the taxation on loans to a...more

Cadwalader, Wickersham & Taft LLP

A Toothless Tax Avoidance Scheme: M Northwood v HMRC

The UK’s First-tier Tribunal (“FTT”) has denied a taxpayer a deduction for contributions to a remuneration trust on the basis that such payments did not give rise to an expense under generally accepted accounting principles...more

BCLP

Spring Budget 2023 - tax impact on the real estate sector

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Underneath the headline points, the Budget contained a number of measures designed to fulfil the Chancellor’s objective of encouraging growth and investment. There was broadly good news for those investing in UK real estate....more

Cadwalader, Wickersham & Taft LLP

HMRC v BlackRock Holdco 5 LLC Throws a Spotlight on UK Transfer Pricing and the ‘Unallowable Purposes’ Rule

A decision in late-July 2022 of the UK’s Upper-tier Tax tribunal (“UTT”) has held that interest recognized by a UK resident company on loan notes issued to its parent was non-deductible under the UK transfer pricing rules, as...more

Hogan Lovells

Potential additional hurdle to clear if interest on intra-group debt is to be tax deductible in the UK

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In applying the UK’s transfer pricing rules, tax advisers have to think beyond the amount of the debt and the interest rate to get comfortable that an intra-group loan is going to be tax deductible. Following a recent case,...more

Proskauer Rose LLP

UK Tax Round Up - May 2022

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Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

Proskauer Rose LLP

UK Tax Round Up - January 2022

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UK Case Law Developments - Contributions to remuneration trust scheme not tax deductible - In Strategic Branding Ltd v HMRC, the First-tier Tribunal (FTT) held that sums contributed by the taxpayer company to a...more

Proskauer Rose LLP

UK Tax Round Up - October 2021

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The Chancellor presented the Budget on 27 October. Although it contained a wide range of general spending and tax-related announcements, there was nothing of significance for the private funds industry that had not been...more

White & Case LLP

Top considerations –EMEA Tax trends impacting Private Equity Real Estate in 2021

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White & Case has advised a large number of high-profile international clients on cutting-edge, cross-border and domestic private equity real estate deals, providing valuable strategic tax insight to a broad range of investors...more

BCLP

UK Budget 2021 - The Data Centre spin on super-deductions

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In the UK budget on 3 March, Rishi Sunak, the Chancellor, announced a significant improvement in tax relief for a two year period that may make the data centre industry sit up and consider investing in new equipment between 1...more

Proskauer Rose LLP

UK Tax Round Up - May 2020

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UK COVID-19 developments - Proposed deferral of DAC6 and DAC2 - The European Commission has published a draft directive proposing a three month delay to the deadlines for certain information disclosures under the EU...more

Hogan Lovells

Budget 2020: real estate tax changes

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Here is a brief summary of the measures in the March 2020 Budget which are relevant to the Real Estate sector. Non-UK resident companies with UK property income – As previously announced, non-UK resident companies that...more

BCLP

UK makes amendments to regime for agents withholding tax on rent paid to non-resident corporate landlords

BCLP on

The Government has amended the existing non-resident landlord scheme regulations (S.I. 1995/2902) in readiness for the transition to corporation tax for non-resident corporate landlords from 6 April 2020. The changes impact...more

White & Case LLP

European Real Estate Finance: Recent developments – June 2019

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As part of our periodic updates, here is an overview of recent developments of relevance to participants in the real estate finance market across certain key jurisdictions in Europe....more

Cadwalader, Wickersham & Taft LLP

UK Budget 2018 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2018 on 29 October 2018. The Budget was delivered against the backdrop of the UK’s negotiations with the European Union concerning Brexit. ...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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The White House has made it official and nominated Fed governor Jerome Powell as the next Chair of the Federal Reserve. Powell is expected to continue the basic fiscal (though not necessarily regulatory) policies of the...more

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