The Capital Ratio Podcast | Entering the US Banking Market
Great Women in Compliance: GWIC X EC Q2 2025 - Exploring Compliance Innovations
An Ounce of Prevention Podcast | The International Anti-Corruption Prosecutorial Taskforce and the Future of Global Enforcement
The LathamTECH Podcast — Where Digital Assets Slot Into a Shifting Fintech Regulatory Landscape: Insights From the US, UK, and EU
10 For 10: Top Compliance Stories For the Week Ending May 24, 2025
Daily Compliance News: May 23, 2025, The Gutless Wonders Edition
Daily Compliance News: May 21, 2025, The I Want You Back Edition
Everything Compliance: Episode 153, The CW 25 Edition
10 For 10: Top Compliance Stories For the Week Ending, May 3, 2025
Daily Compliance News: April 30, 2025, The 4 AM Wake-Up Call Edition
The Capital Ratio Podcast | Stablecoins: Regulatory Issues for UK and EU Banks To Consider
An Ounce of Prevention Podcast | Preparing for the UK Failure to Prevent Fraud Offence
Compliance into the Weeds: Global Anti-Corruption Leadership
Daily Compliance News: March 24, 2025, The ABC Task Force Edition
Daily Compliance News: March 18, 2025, The Slack Channel Edition
Podcast — UK FinReg Focus Areas in 2025: Retail Markets
Podcast — UK FinReg Focus Areas in 2025: Wholesale Markets
Fintech Focus Podcast | Navigating IT and Security Risks in Fintechs in Light of Impending DORA Deadline
The Standard Formula Podcast | The SFCR and Other Public Reporting: A Solvency II Cornerstone
Fintech Focus Podcast | Sanctions Compliance: Regulators Set Their Sights on Fintechs
Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more
On 28 April 2025, the UK government launched a consultation (the “Consultation”) on proposed legislation to reform the UK’s transfer pricing (“TP”) and permanent establishment (“PE”) rules, including changes to the investment...more
On 28 April 2025, HM Revenue and Customs (HMRC) proposed significant reforms to the UK’s transfer pricing and permanent establishment (PE) rules, and a repeal of the diverted profits tax, bringing that regime within UK...more
Welcome to April’s edition of our UK Tax Round Up. While this month has been quiet on the case law front, there have been a number of HMRC announcements and updates to prior published guidance along with published responses...more
Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the...more
Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting decisions covering the application of the transfer pricing rules and the unallowable purpose test to an intragroup financing...more
The attractiveness of the United Kingdom as a business location is unabated. There are many advantages to doing business in the UK. Investors can draw on a skilled workforce and access a large market; costs of labour and...more
HMRC has published a consultation paper anticipating reforms to the UK’s rules on transfer pricing, permanent establishments and diverted profits tax. This is a wide-ranging review and it may be that its constituent parts...more
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
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
When applying the UK’s transfer pricing rules to compare an intra-group loan to the hypothetical arm’s length transaction that an independent third-party lender would have agreed to, there is no scope to read in covenants...more
Welcome to July’s edition of the UK Tax Round Up. This month has seen an interesting decision of the First-tier Tribunal on the salaried member rules as they apply to asset manager LLPs, a surprising decision on the terms...more
This was an appeal against the High Court decision in Dodika Ltd & Ors v United Luck Group Holdings Limited from August 2020 (see our Tax Blog on this). The case concerns the question of whether the notice given by the buyer...more
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
In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers’ argument that a notice of a tax claim under a tax covenant served on them by the buyer was invalid because it did not...more
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
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
The policy behind SDIL is to reduce childhood obesity by encouraging producers to change the recipes and lower the sugar content of the drinks. The Government estimates that over 50% of manufacturers had done so before SDIL...more
It’s been a busy month in the world of tax for tech companies. France and the UK are introducing digital services taxes, and serious work is underway at the OECD that may result in a shake-up of the international tax system...more
The UK tax authority, HMRC, recently announced the introduction of a new Profit Diversion Compliance Facility, which is aimed at tackling the avoidance of tax by diverting profits outside the UK without proper economic...more
The UK tax authority (HMRC) has announced a new Profits Diversion Compliance Facility (PDCF), as part of its efforts to ensure that multinationals do not use artificial arrangements to divert profit to lower tax...more
HMRC has announced today the introduction of a new Profits Diversion Compliance Facility, which is aimed at tackling the avoidance of tax by multinationals by diverting profits outside the UK without proper economic...more