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United Kingdom European Union Tax Planning

Carey Olsen

Guernsey funds – special considerations for US managers

Carey Olsen on

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

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

Latham & Watkins LLP

Navigating Debt Repurchases in Europe: What You Need to Know - October 2022 #2

Latham & Watkins LLP on

This Client Alert examines the key issues that typically arise in connection with debt repurchase programs. It also looks at issues applicable to both bond and loan repurchases, as well as jurisdictional issues raised by the...more

Katten Muchin Rosenman LLP

Katten Corporate and Real Estate Tax Case Roundup – February 2022

In this roundup, we look at some of the key cases in corporate and real estate tax from December 2021 to January 2022, including the value–added tax (VAT) decisions on input VAT that was not passed on to final consumers and...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

Hogan Lovells

Important changes to DAC6 regime in the UK

Hogan Lovells on

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

Morgan Lewis

Changes to UK DAC 6 Reporting Requirements

Morgan Lewis on

Coinciding with the end of the UK-EU Brexit transition period, the United Kingdom has dramatically reduced the scope of DAC 6 reporting obligations in the United Kingdom. ...more

Cooley LLP

Alert: Brexit Readiness: Possible Key Impacts of the Conclusion of the Transition Period on 31 December 2020

Cooley LLP on

On 31 January 2020, the UK left the European Union and entered a transition period that is due to end at 11:00 pm GMT on 31 December 2020. At this point, it is still uncertain whether a new EU/UK deal will be reached. To...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

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 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

White & Case LLP

DAC6 reporting delay proposed by EU Commission due to COVID-19

White & Case LLP on

DAC6 summary - Council Directive 2018/822 – known as DAC6 – is the sixth amendment to the EU Directive on Administrative Cooperation 2011/16/EU. DAC6 is aimed at providing the tax authorities with a “warning system” in...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

White & Case LLP

Real estate joint ventures: Marriage of equity and expertise

White & Case LLP on

The asset manager's expertise, coupled with the investor's capital, allows both parties to maximise their respective returns. Real estate has always had a strong appeal to investors. Property yields have been outperforming...more

Proskauer Rose LLP

UK Tax Round Up - October 2019

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UK Case Law Developments - Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation - In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more

Proskauer Rose LLP

UK Tax Round Up - September 2019

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Case Law Developments - Place of supply for VAT purposes - The recent case of American Express Services Europe Limited (AESEL) v HMRC is a useful reminder of the well-established two-stage approach to determining the...more

Proskauer Rose LLP

UK Tax Round Up - September 2018

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UK Case Law Developments - Entrepreneurs' relief – voting rights not imputed for equitable reasons - In George v HMRC, the First Tier Tribunal (FTT) decided that they could not apply the equitable principle that...more

Proskauer Rose LLP

UK Tax Round Up - April 2018

Proskauer Rose LLP on

General UK tax developments - Changes to taxation of termination payments - HMRC has updated its Employment Income Manual to reflect the changes to the taxation of termination payments (including payments in lieu of...more

Proskauer Rose LLP

UK Tax Round Up - February 2018

Proskauer Rose LLP on

Case law developments - Settlement payment not deductible as an expense of a trade (Vaines v HMRC) - Mr. Vaines was a solicitor. In the 2007/08 tax year he paid a settlement amount to a third party that had made a...more

Proskauer Rose LLP

UK Tax Round Up - January 2018

Proskauer Rose LLP on

The impact of discounts on consideration for VAT purposes (Finanzamt Bingen-Alzey v Boehringer Ingelheim Pharma GmbH & Co. KG) - The ECJ has confirmed that consideration for VAT purposes should be reduced by any discount...more

McDermott Will & Schulte

McDermott International Legal Highlights November 2016

McDermott Will & Schulte on

The New World of Global Tax Planning: a Checklist for Success - As all multinationals (MNEs) are discovering, domestic implementation of the recommendations set out in the base erosion and profit shifting (BEPS) final...more

McDermott Will & Schulte

Focus on Tax Strategies & Developments - August 2016

Brexit: The Consequences for International Tax Planning - Just over a month has now passed since the referendum in which the United Kingdom voted narrowly to leave the European Union: an event which some have...more

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