Death, Taxes and Politics: The Future of Tax Policy Ahead of the 2024 Election
Starting from January 2025, staff secondments are subject to VAT even where limited to the mere reimbursement of costs, provided that the relevant payment received qualifies as consideration for a supply of services. This...more
Cada año, el Servicio de Impuestos Internos (SII) actualiza la guía denominada Catálogo de Esquemas Tributarios, que contiene un listado de operaciones que pueden ser declaradas elusivas por aplicación de la Norma General...more
Previously, for credit insurance covering the price of a supply including VAT, in so far as the credit insurer was subrogated in the rights of the insured supplier, the insurer was entitled to exercise the VAT refund right...more
On 16 January 2025, the President ratified Supplementary Law No. 214/2025, marking a significant step in Brazilian tax reform. This new law outlines the framework for the IBS, the CBS, and IS, while also establishing the IBS...more
The modification of the French administrative guidelines puts an end to an asymmetrical situation where the taxpayers had 2 years to claim incorrectly invoiced VAT and the French tax authorities had 3 years to reassess...more
The issue of the taxability of intra-group supplies in the context of a VAT group has been of concern to taxpayers for many years. The starting point was the question of whether a VAT group existed between a foundation under...more
Company belonging to Euro 750 Mio Group, will pay DST regardless of their digital service turnover in Italy. ...more
In Barclays Service Corporation and another v HMRC, the First Tier Tribunal (the “FTT”) has held that the UK branch of an overseas company did not qualify as a member of a value added tax (“VAT”) group in the UK....more
The government has just issued an amendment n°5374 to the draft Finance Bill for 2024 aimed at clarifying the VAT regime applicable to the para-hotel and serviced residences sector, following the Administrative Supreme Court...more
Whilst the default position is that supplies of land and buildings are usually exempt from VAT (the sale of new commercial buildings excepted), landowners of commercial property will often choose to opt to tax their property...more
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
HM Revenue and Customs (HMRC) now considers that charges made by businesses to their customers to withdraw early from agreements to supply goods or services are payments for a supply and potentially subject to value added-tax...more
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
UK General Tax Developments - Stamp Duty and COVID-19 - Since the start of the first UK lockdown in March 2020, HMRC has been accepting that documents can be stamped electronically. HMRC has now confirmed that, where...more
The UK government is pressing ahead with its proposal to require large businesses to notify their “uncertain tax positions” to HMRC. ...more
UK Case Law Developments - Tax avoidance motive did not prevent availability of share for share exchange treatment - In Euromoney Institutional Investor plc v HMRC, the FTT held that the share for share exchange...more
Spring Budget and Tax Day - After months of speculation about the possibility that capital gains tax (CGT) rates would be increased in the Spring Budget, both it and the government’s follow up “Tax Day” on 23 March passed...more
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
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
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
Quick Summary. In the United Kingdom, Her Majesty’s Revenue and Customs (HMRC) is responsible for administering and collecting taxes in the UK. For 2019, HMRC collected $841.19 billion in tax revenue. But it took over 300...more
UK COVID-19 Developments - UK Prime Minister’s statement on COVID-19 - On 31 October, the Prime Minister announced a number of measures designed to slow down the spread of COVID-19 to last for four weeks from 4...more
Finance Act 2020: This Time It’s Personal (Liability) - The Finance Act 2020 introduces new rules which make certain individuals who have a ‘relevant connection’ to a company that is, or is likely to become, subject to an...more
With effect from 1 December 2020, the UK’s HM Revenue & Customs will be given preferential creditor status for certain taxes which a company has collected but failed to pay to HMRC on the date it enters insolvency. ...more
UK COVID-19 Developments - HMRC updates its trading activities guidance - HMRC has updated its guidance at BIM48000 regarding how legislation and case law should be applied where a business makes changes to its...more