Double taxation relief

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Practice notes
Nature and classification of trusts—the three certaintiesCertaintyIn order for a settlor to create a private express trust the three certainties must...
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19th May
Practice notes
Private Client—Luxembourg—Q&A guideTaxation regimeWhat factors determine tax liability in your jurisdiction (eg domicile, residence or...
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Produced in partnership with Eric Fort of Arendt & Medernach 19th May
Practice notes
Creation of trusts—beneficiariesWho may be beneficiariesEvery person who would be capable of owning property if of full age and sound mind may be a...
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19th May
Practice notes
CGT—giftsA gift of an asset is a disposal for capital gains tax (CGT) purposes. It can, therefore, trigger a CGT charge on the gain deemed to have...
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Produced in partnership with Laura Poots (Barrister) of Pump Court Tax Chambers 19th May
Practice notes
CGT—reliefsFORTHCOMING CHANGE: On 14 July 2020, the Office of Tax Simplification (OTS) published its online survey and a call for evidence to seek...
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19th May
Q&As
When can a mistake in an executed deed be rectified by a manuscript amendment rather than by a deed of rectification?This Q&A explains when it is...
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Produced in partnership with Emma Holland of Stewarts Law 19th May
Precedents
This Deed OF REVOCATION is made on [date] by me [name of donor] of [address of donor].This Deed provides:1Revocation...
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19th May
Practice notes
Trustees—statutory powers of trusteesSource and availabilitySourcesTrustees have certain powers conferred on them by statute, in particular by the...
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19th May
Practice notes
Trustees—removal of trusteesA trustee may be removed against their will in any of the following ways:•under an express power in the trust...
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19th May
Practice notes
The Cy-près doctrineFORTHCOMING CHANGE: On 22 March 2021, the government published its response  to the Law Commission’s report of 14 September 2017,...
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19th May
Q&As
Can a life tenant in a Will bring a life interest to an end by choosing to end it themselves or does it only expire on death?Life tenantsA life...
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Produced in partnership with Lynne Counsell of 9 Stone Buildings 19th May
Practice notes
Costs and expenses in the Court of ProtectionThere are court fees and disbursements which will be payable by all applicants on making a new...
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19th May
Practice notes
Trust disputes—court jurisdiction and procedureTrust litigation has been classified as being of three types:•a dispute as to the trusts on which...
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19th May
Practice notes
Offshore trusts—offshore income gains (OIGs)Offshore income gains (OIGs) are gains realised on the disposal of interests in offshore funds which are...
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19th May
Practice notes
Trustees—self-dealing, unauthorised profits and conflicts of interestThe self-dealing ruleThe self-dealing rule is connected to, but distinct from,...
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19th May
Practice notes
Trustees—power of advancementWhere a beneficiary either:•is a minor (ie under the age of 18) and unmarried or•has attained majority or has married...
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19th May

Most recent Double taxation relief content

Practice notes
Glossary of UK trust and taxation law terms for international clientsAAdministrationThe process starting on the date of the deceased's death and...
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1st Jul
Practice notes
Royalties articles in double tax treatiesArticle 12 of the OECD model tax convention (OECD model convention) is concerned with the taxation of...
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Produced in partnership with David Klass of Hunton Andrews Kurth 21st Jun
Practice notes
Principles of interpretation of double tax treatiesDouble tax treaties or conventions (DTTs) have a dual nature. They are:•conventions between states...
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Produced in partnership with David Klass of Hunton Andrews Kurth 21st Jun
Practice notes
Interest articles in double tax treatiesArticle 11 of the OECD model convention is concerned with the taxation of interest paid cross border. In...
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Produced in partnership with David Klass of Hunton Andrews Kurth 21st Jun
Practice notes
Dividend articles in double tax treatiesArticle 10 of the OECD model convention is concerned with the taxation of dividends paid cross border. In...
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Produced in partnership with David Klass of Hunton Andrews Kurth 16th Jun
Q&As
What are the UK’s automatic exchange of information obligations with Guernsey?What are the UK’s automatic exchange of information obligations with...
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6th Jun
Q&As
What tax implications are there (NIC etc) for someone based in the UK, but carrying out tasks for a company overseas?The concepts of residence and...
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6th Jun
Practice notes
Double taxation relief—summaryInternational tax law is mostly concerned with the taxing rights of states. As with all forms of international law, the...
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5th Jun
Practice notes
Key definitions and concepts relating to double tax treatiesThis Practice Note explains some of the key definitions and concepts a tax lawyer will...
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Produced in partnership with David Klass of Hunton Andrews Kurth 5th Jun
Practice notes
Anti-avoidance and double tax treatiesWhat are the anti-avoidance concerns in a double tax treaty context?As discussed in Practice Note: What are...
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Produced in partnership with David Klass of Hunton Andrews Kurth 5th Jun
Practice notes
What are double tax treaties?Double tax treaties (DTTs) allocate taxing rights between jurisdictions, with the primary aim of ensuring that taxpayers...
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Produced in partnership with David Klass of Hunton Andrews Kurth 5th Jun
Practice notes
Claiming relief under a double tax treaty in relation to income or gains from UK real estateMany investors in UK property are based outside the UK....
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Produced in partnership with Charles Goddard of Rosetta Tax 5th Jun
Practice notes
Unilateral relief—UK IHTUnilateral relief may be available as a credit against UK inheritance tax (IHT) where a tax of a character similar to IHT has...
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Produced in partnership with Andrew Godfrey and Yousafa Hazara of Russell-Cooke Solicitors LLP 5th Jun
Practice notes
Assistance in collection in tax mattersIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period...
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Produced in partnership with David Klass of Hunton Andrews Kurth 5th Jun

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