Tax Planning, Corporate Taxes, Holding Companies

Key UK Tax Implications of the Delaware Flip

Wilson Sonsini Goodrich & Rosati on 6/2/2025

U.S. venture capitalists investing at the early stages (Seed and Series A) in a UK (or other non-U.S.) company often require that the company “flips” its corporate structure and establishes a U.S. (most commonly Delaware)...more

Nordcurrent: Interpreting Anti-Abuse Rules

Cadwalader, Wickersham & Taft LLP on 5/29/2025

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

The UK Qualifying Asset Holding Company Regime - Highlights

Orrick, Herrington & Sutcliffe LLP on 3/31/2022

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

UK Tax Round Up - November 2021

Proskauer Rose LLP on 12/3/2021

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

UK Tax Round Up - December 2020

Proskauer Rose LLP on 1/5/2021

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

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

McDermott Will & Schulte on 6/2/2020

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