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Practice notes
How employment income is taxed—non-cash earnings or benefitsIn addition to cash earnings, such as wages or salaries, many reward packages include...
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19th May
Practice notes
What is an intangible fixed asset?Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQsWhat are the CDOT agreements?The UK entered into agreements with its three Crown...
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Produced in partnership with Ali Kazimi of Hansuke 19th May
Practice notes
VAT treatment of damages and compensation paymentsFORTHCOMING CHANGE: HMRC is in the process of revising Revenue and Customs Brief 12 (2020) on the...
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19th May
Practice notes
Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
EIS—deferred gain becomes chargeable to CGTCoronavirus (COVID-19): In response to the coronavirus (COVID-19) pandemic, the government introduced a...
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19th May
Practice notes
Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the...
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19th May
Practice notes
Corporation tax—connected personsThis Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act...
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19th May
Practice notes
Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
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19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May

Most recent International content

Practice notes
The UK as a holding company jurisdiction—tax considerationsThis Practice Note focuses on the characteristics of the UK as a tax-efficient holding...
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Produced in partnership with Andrew Howard of Ropes & Gray 2nd Aug
Q&As
Can a non-UK incorporated company have a UK taxable presence if it has an employee operating in the UK?Whether a single employee working in the UK for...
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1st Aug
Q&As
Does the UK (or HMRC in practice) express a preference for a particular transfer pricing method for establishing an arm’s length price of interest,...
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1st Aug
Q&As
What tax issues should be considered when transferring a non-UK company to a UK company in a share for share exchange?Where a non-UK company is...
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1st Aug
Q&As
What are the key potential tax and legal implications of having a non-UK director on the board of directors of a UK company?Before introducing a...
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1st Aug
Q&As
Is an employee of a UK employer liable to UK National Insurance contributions if the employee works solely from abroad and is not liable to UK income...
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Produced in partnership with Denis Edwards of Normanton Chambers 1st Aug
Q&As
Which types of persons are within the UK transfer pricing regime?The UK’s transfer pricing regime applies to ‘persons’ and therefore includes...
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1st Aug
Q&As
Is interest charged on underpaid import value added tax (VAT) pursuant to the statutory VAT provisions or the statutory customs provisions?Interest on...
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1st Aug
Q&As
What method will HMRC use when determining an arm's length interest rate on a related party loan?In this Q&A we have assumed that the lending in...
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1st Aug
Q&As
Should UK income tax be withheld from royalty payments made by a UK company to a UK charity?As noted in Practice Note: Withholding tax on royalties,...
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1st Aug
Q&As
Does UK withholding tax apply to the payment of dividends?As set out in Practice Notes: UK withholding tax on yearly interest and Withholding tax on...
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1st Aug
Q&As
Does a non-UK entity need to have a UK bank account in order to register for VAT in the UK and recover input tax?We are not aware that there is a...
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1st Aug
Q&As
When a non-UK company has a UK permanent establishment or becomes UK tax resident, how and when must it inform Companies House and HMRC? What happens...
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1st Aug
Q&As
Coronavirus (COVID-19)—what is the impact of the coronavirus-related restrictions on corporate tax residence and permanent establishments?Any...
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Produced in partnership with Martin Shah 1st Aug
Q&As
Coronavirus (COVID-19)—what are the potential tax consequences of working remotely, including cross-border employment tax issues?As a result of...
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Produced in partnership with Laura Allwright of Simmons & Simmons and Darren Oswick of Simmons & Simmons 1st Aug
Practice notes
Practical guidance on the taxation of share options for internationally mobile employeesThis Practice Note summarises the taxation of internationally...
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Produced in partnership with Lewin Higgins-Green of FTI Consulting 1st Aug
Q&As
Is a licence of intellectual property by an Australian company to a UK private individual subject to UK VAT?In order to assess whether a cross-border...
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1st Aug
Q&As
Do the rules that tax profits from trading in and developing UK land affect the UK withholding tax rules?The rules introduced in Finance Act 2016 (FA...
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1st Aug

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