Saffery Champness



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Saffery Champness
Contributions by Saffery Champness Experts


Demergers—an introduction to the tax issues
Practice notes

This Practice Note looks at the reasons for carrying out a demerger, introduces the different demerger mechanisms, and summarises the tax issues associated with each route. It also describes some typical steps that may be taken as part of a pre-demerger restructuring. This Practice Note was produced in partnership with Robert Langston of Saffery Champness and Zoe Feller of Bird & Bird.

Dual resident investing companies (DRICs)
Practice notes

This Practice Note explains the key anti-avoidance rules applying in the UK to dual resident investing companies (DRICs), and also discusses what constitutes a DRIC for UK tax purposes.

Entity classification case law and HMRC's interpretation
Practice notes

This Practice Note explains the circumstances in which overseas entities are classified as either transparent or opaque for UK tax purposes by reference to the applicable case law (eg Dreyfus, Ryall v The DuBois Company, Memec and Anson) and HMRC’s interpretation and views on entity classification. Produced in partnership with Robert Langston of Saffery Champness.

UK tax implications of overseas entity classification and distributions from overseas entities
Practice notes

An overseas entity may be characterised for UK tax purposes as transparent or opaque. This Practice Note explains how this classification will affect how the entity, and its members, are taxed in the UK. The taxation of distributions from opaque overseas entities is considered, as well as considerations such as hybrid entities, permanent establishments, double tax treaty relief, and certain anti-avoidance rules.

Other Work
Classifying overseas entities for UK tax purposes—checklist

This Checklist is for use when determining whether an overseas entity will be treated as transparent or opaque for UK tax purposes.

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