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Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
Practice notes
It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a sale of all the shares...
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9th Nov
Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes
FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan
Practice notes
Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan
Practice notes
Stamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that...
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9th Nov
Practice notes
FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...
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9th Nov
Practice notes
Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to the gains and losses of intangible...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 12th Jan

Most recent International content

Q&As
Transfer pricing rules in the UK and elsewhere require that transactions between connected parties are recognised for tax purposes by applying the...
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29th Nov
Precedents
[Letterhead][Addressed to reporting body’s customer relationship manager (CRM) or, if none, the office to which the reporting body’s corporation tax...
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29th Nov
Q&As
The UK’s transfer pricing regime applies to ‘persons’ and therefore includes individuals and firms (partnerships), as well as companies. For more, see...
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29th Nov
Q&As
Before introducing a non-UK tax resident individual as a director of a UK company, the company should obtain advice from UK and non-UK tax advisers to...
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29th Nov
Q&As
In this Q&A we have assumed that the lending in question is between two companies (or is within the same company) rather than between individuals,...
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29th Nov
Q&As
The rules introduced in Finance Act 2016 (FA 2016) that tax Profits from trading in and developing UK land (transactions in UK land) did not make any...
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29th Nov
Q&As
As set out in Practice Notes: UK withholding tax on yearly interest and Withholding tax on royalties, UK tax law generally requires the payer to...
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29th Nov
Q&As
Unless an exemption or relief applies, payments of UK source yearly interest (or amounts that are treated by tax legislation as payments of yearly...
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29th Nov
Q&As
Can an entity be a ‘connected [person]’ as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an ‘associated company’ with the...
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29th Nov
Q&As
The disguised interest rules apply to ‘returns economically equivalent to interest’. For income tax purposes, the rules state that these returns are...
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29th Nov
Q&As
Where there is an obligation to withhold tax on interest, that obligation arises when interest is paid.Generally, interest is paid when there is an...
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29th Nov
Q&As
We are not aware that there is a legal obligation to have a UK bank account in order to register for value added tax (VAT). HMRC forms for registering...
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29th Nov
Q&As
Where a non-UK company is transferred to a UK incorporated and tax-resident company by way of a share for share exchange, there are numerous potential...
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26th Nov
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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26th Sep
Precedents
1 Authority of directors The business of the company shall be managed by the directors, who may exercise all such powers of...
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26th Sep

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