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Carey Olsen

Guernsey funds – special considerations for US managers

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Guernsey, located in the English Channel, is one of the world’s largest offshore finance centres, with a thriving funds industry. The value of funds under management and administration in Guernsey is US$532bn. Guernsey is an...more

Walkers

Guernsey Guide: legal, regulatory, transparency and supervisory framework

Walkers on

This briefing explains Guernsey’s adoption of rigorous international tax and regulatory standards, which, in conjunction with its local tax law, make it an ideal location for investment funds and other investment vehicles....more

Cadwalader, Wickersham & Taft LLP

UK VAT Treatment of Fund Management Review Announced

As part of the Edinburgh Reforms announced by the UK Government (link back to “UK FS Reforms”), the UK Government has launched a public consultation on the VAT treatment of fund management. The consultation, published on 9...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

Orrick, Herrington & Sutcliffe LLP

Russian Exposure: Guidance for Tech Companies

This guidance does not constitute legal advice. To the extent that you have any questions arising out of the guidance, please speak to a member of the Orrick team who will be happy to assist. The invasion of Ukraine by...more

McDermott Will & Schulte

International News: Spotlight on Tax

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...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

Holland & Knight LLP

U.K., U.S. Reach Competent Authority Agreement on "Equivalent Beneficiary" Status

Holland & Knight LLP on

The United Kingdom and the U.S. Competent Authorities published on July 28, 2021, a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty). It provides for purposes of...more

Eversheds Sutherland (US) LLP

Partial Brexit? For income tax treaty purposes, US and UK competent authorities vote to remain 

While the United Kingdom left the European Union (EU) last year, the competent authorities of United States and United Kingdom have agreed that the United Kingdom will remain in the EU for purposes of the US-UK Income Tax...more

Proskauer Rose LLP

UK Tax Round Up - February 2021

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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

Katten Muchin Rosenman LLP

DAC6: Adieu to EU

On the eve of the UK's exit from the EU on 31 December 2020, the UK Government published the concise but game-changing piece of legislation, 'The International Tax Enforcement (Disclosable Arrangements) (Amendment) (No. 2)...more

Skadden, Arps, Slate, Meagher & Flom LLP

Antitrust and the EU-UK Trade and Cooperation Agreement

The European Union (EU)-U.K. Trade and Cooperation Agreement (TCA) governing post-Brexit trade relations between the U.K. and the EU includes provisions regulating EU/U.K. antitrust enforcement and cooperation effective...more

Hogan Lovells

Important changes to DAC6 regime in the UK

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The UK has made important changes to its implementation of the EU Mandatory Tax Disclosure Rules known as DAC6. The changes, which significantly reduce the scope of the rules in the UK, are largely good news for UK taxpayers...more

McDermott Will & Schulte

United Kingdom Repeals All But One of DAC6 Reporting Triggers

Despite much anticipation to the contrary, the UK Government decided to repeal all but one of the reporting triggers under the UK regulations implementing EU Council Directive 2018/822 on the reporting of cross-border tax...more

Proskauer Rose LLP

UK Tax Round Up - November 2020

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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

Hogan Lovells

Beyond Brexit transition – VAT on cross-border movement of goods

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Businesses moving goods to or from Great Britain will face new compliance burdens. EU businesses making sales to UK customers may have to register for UK VAT for the first time....more

McDermott Will & Schulte

[Webinar] International Tax Transparency Update - November 18th, 3:00 pm GMT

McDermott Will & Schulte on

Our International Tax Transparency Update will cover DAC6, the UK’s Trust Registration Service and other global registration requirements that may be relevant for businesses. The importance of these requirements cannot be...more

Proskauer - Tax Talks

HMRC updates its guidance on the VAT treatment of early termination fees and compensation payments

Proskauer - Tax Talks on

Following the European Court of Justice’s (ECJ) rulings in Meo and Vodafone Portugal, HMRC has recently updated its VAT manual and published a brief...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

Proskauer Rose LLP

UK Tax Round Up - April 2020

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Temporary changes to the statutory residence test for inbound COVID-19 workers - The UK Chancellor has written to the chair of the Treasury Select Committee outlining temporary changes to the statutory residence test...more

Skadden, Arps, Slate, Meagher & Flom LLP

Critical Thinking in the Time of COVID-19: What To Consider Next From a European Tax and State Aid Perspective

In this series, “Critical Thinking in the Time of COVID-19,” our European tax practice examines the next stage of analysis for corporates that have begun digesting the economic and legal impact of COVID-19 on their...more

BCLP

Importance of conformity to international tax standards – Cayman Islands added to the EU blacklist of non-cooperative...

BCLP on

The EU’s Economic and Financial Affairs Council (ECOFIN) maintains a list of non-cooperative jurisdictions for tax purposes; the purpose of which is to contribute to ongoing efforts to promote tax good governance worldwide....more

McDermott Will & Schulte

How CCO Reasonable Prevention Procedures Can Help You Mitigate DAC6 Penalties

Corporate criminal offences (CCOs) under Part 3 Criminal Finances Act 2017 (CFA) are increasingly coming under the spotlight of the UK tax authorities. In a 10 February 2020 press release published in response to a Freedom of...more

Proskauer Rose LLP

UK Tax Round Up - January 2020

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UK General Tax Developments - Date set for next UK Budget - The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more

Proskauer Rose LLP

UK Tax Round Up - November 2019

Proskauer Rose LLP on

UK Case Law Developments - More decisions on IR35 - This month has seen two more decisions on whether broadcast presenters providing their services to the BBC and ITV respectively would or would not have been...more

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