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Double tax treaties

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Latest Tax News

SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

The following Private Client news provides comprehensive and up to date legal information on SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

Tax weekly highlights—22 July 2021

Tax weekly highlights—22 July 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—22 July 2021

Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

The following Tax news provides comprehensive and up to date legal information on Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

Court of Appeal rules that third-party loan servicing is liable to VAT (Target Group Ltd v HMRC)

Court of Appeal rules that third-party loan servicing is liable to VAT (Target Group Ltd v HMRC)

The following Tax news provides comprehensive and up to date legal information on Court of Appeal rules that third-party loan servicing is liable to VAT (Target Group Ltd v HMRC)

Featured Tax content

VAT definition

VAT definition

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Enhanced capital allowances

Enhanced capital allowances

Enhanced capital allowancesWhat is an enhanced capital allowance?An enhanced capital allowance (ECA) is a tax relief for businesses on their...

VAT—what is a transfer of a business as a going concern?

VAT—what is a transfer of a business as a going concern?

VAT—what is a transfer of a business as a going concern?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...

Property authorised investment funds (PAIFs)—summary

Property authorised investment funds (PAIFs)—summary

Property authorised investment funds (PAIFs)—summaryThe regime for property authorised investment funds (PAIFs) was introduced in 2008.It created a...

Practice notes

Direct tax treatment of damages and compensation payments

Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
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19th May
Practice notes

Share sale or asset sale—tax considerations

Share sale or asset sale—tax considerationsThe sale of a company's business can be structured as either:•a sale of assets owned by the company (an...
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19th May
Practice notes

SDLT—deeds of rectification

SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...
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19th May
Practice notes

VAT—triangulation

VAT—triangulationIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 19th May
Practice notes

How employment income is taxed—non-cash earnings or benefits

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

VAT treatment of damages and compensation payments

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
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Practice notes

Key tax consequences of an insolvent liquidation

Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 19th May
tag iconIn-house
Practice notes

Amortisation of intangible fixed assets

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 CGT

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)

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

Tax considerations on a loan agreement—the tax gross up clause

Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Practice notes

Section 198 and 199 elections on transactions involving real estate

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

Taxation of UK LLPs

Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes

Loan capital exemption from stamp duty

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 demergers

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

Transfer of a trade under common ownership

Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May

Most recent Double tax treaties content

Practice notes

Automatic exchange of information—outline

Automatic exchange of information—outlineSTOP PRESS: The government has enacted amending regulations that significantly restrict the scope of the UK’s...
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1st Jul
Practice notes

Royalties articles in double tax treaties

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 treaties

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 treaties

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 treaties

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
Practice notes

Non-discrimination in double tax treaties

Non-discrimination in double tax treatiesNon-discrimination and Article 24 of the OECD model conventionNon-discrimination is a term that is used...
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Produced in partnership with David Klass of Hunton Andrews Kurth 15th 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 Guernsey?What are the UK’s automatic exchange of information obligations with...
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6th Jun
Q&As

Can a double tax treaty relief claim be made for withholding tax paid to HMRC in the form of a funding bond?

Can a double tax treaty relief claim be made for withholding tax paid to HMRC in the form of a funding bond?Unless an exemption or relief applies,...
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6th Jun
Q&As

A trust whose trustees are resident in India, has income and gains that are primarily taxable in India under the UK-India double taxation treaty. If the trustees make a distribution to a UK-resident beneficiary of the trust, what relief is available to avoid the income and gains from being subject to UK tax if the beneficiary remits the income and gains to the UK?

A trust whose trustees are resident in India, has income and gains that are primarily taxable in India under the UK-India double taxation treaty. If...
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5th Jun
Practice notes

Offshore disclosure facilities—outline

Offshore disclosure facilities—outlineSince 2007, HMRC has offered a series of disclosure facilities to individuals with offshore investments. These...
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5th Jun
Practice notes

The syndicated loan scheme (SLS)

The syndicated loan scheme (SLS)Unless an exemption or a relief applies, a payment of yearly interest arising in the UK (ie with a UK source) is...
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5th Jun
Practice notes

Key definitions and concepts relating to double tax treaties

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 treaties

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?

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 estate

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

Assistance in collection in tax matters

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
Practice notes

The double taxation treaty passport scheme (DTTP scheme)

The double taxation treaty passport scheme (DTTP scheme)The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and...
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5th Jun
Practice notes

The OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAATM)

The OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAATM)This Practice Note provides an introduction to the...
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5th Jun
Practice notes

Liechtenstein Disclosure Facility [Archived]

Liechtenstein Disclosure Facility [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.The Liechtenstein Disclosure Facility...
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5th Jun
Practice notes

The BEPS Multilateral Instrument

The BEPS Multilateral InstrumentThe Organisation for Economic Cooperation and Development (OECD)’s Multilateral Convention to Implement Tax Treaty...
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5th Jun

Popular documents

Contract variation

Contract variation

Contract variationThis Practice Note summarises the law, guidance and practice relating to the variation of contracts and deeds. It explains how a contract or deed can be varied in writing, orally or by conduct, and also considers unilateral variation, waiver and sustained minor breach. It sets out

Admissibility of hearsay evidence in criminal proceedings

Admissibility of hearsay evidence in criminal proceedings

Admissibility of hearsay evidence in criminal proceedingsHow to identify hearsayThe definition of hearsay is contained in the Criminal Justice Act 2003 (CJA 2003). It comprises of four essential elements.There must be:•a statement•made out of court•relied on for the truth of the matter stated,

Direct effect of EU law

Direct effect of EU law

Direct effect of EU lawWhat is direct effect of EU law?The doctrine of direct effect is a fundamental principle of EU law developed by the Court of Justice of the European Union in Van Gend en Loos. It is a mechanism through which individuals can enforce rights in Member States’ courts, based on EU

ECHR, art 5(4)—rights and duties

ECHR, art 5(4)—rights and duties

ECHR, art 5(4)—rights and dutiesThe scope of article 5(4) Article 5(4) of the European Convention of Human Rights (ECHR) provides that: 'Everyone who is deprived of his liberty by arrest or detention shall be entitled to take proceedings by which the lawfulness of his detention shall be decided