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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
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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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
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 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
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 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
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

Practice notes
Foreign branch exemption—anti-diversion after 1 January 2013This note only deals with the foreign branch exemption anti-diversion rules that apply to...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 15th May
Practice notes
When a company is UK tax residentA company is UK tax resident if it is:•incorporated in the UK (subject to exceptions), or•centrally managed and...
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15th May
Practice notes
Internationally mobile employees and securities options (pre-6 April 2015) [Archived]ARCHIVED: This Practice Note has been archived and is not...
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15th May
Practice notes
VAT—the reverse charge on cross-border suppliesAs further explained in Practice Note: What is VAT?, ordinarily:•an amount equal to the VAT due on a...
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Produced in partnership with Michael Ridsdale of Wedlake Bell LLP 15th May
Practice notes
UK withholding tax on yearly interestUnless an exemption or a relief applies, a payment of UK source yearly interest is subject to UK withholding tax...
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15th May
Practice notes
Tax controversy—Taiwan—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to tax controversy in Taiwan published as part of the...
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15th May
Practice notes
Tax controversy—United Arab Emirates—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to tax controversy in United Arab Emirates...
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15th May
Practice notes
Tax on inbound investment—Switzerland—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to tax on inbound investment in...
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15th May
Practice notes
UK tax aspects of cross-border IP structuring—exploitation of IPThis Practice Note sets out the UK perspective on various tax issues that should be...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 15th May
Practice notes
Structure of the foreign branch exemptionPurpose of the regimeThe purpose of the foreign branch exemption is to exempt from UK corporation tax the...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 15th May
Practice notes
Transfer pricing—Netherlands—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to transfer pricing in Netherlands published as...
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15th May
Practice notes
When is the UK participation condition met?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation...
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Produced in partnership with Robert Langston of Saffery Champness 15th May
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 15th May
Practice notes
CFC rules—entity level exemptions: exempt periodThis Practice Note deals with the controlled foreign company (CFC) rules that apply for accounting...
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15th May
Practice notes
Exemption from UK withholding tax on interest and royalty payments made to an associated EU resident company before 1 June 2021This Practice Note is...
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15th May
Practice notes
Old CFC rules—creditable tax [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note deals with the...
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15th May
Practice notes
Foreign branch exemption—historic lossesWhy are special rules required to deal with historic losses?As further explained in Practice Note: UK taxation...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 15th May
Practice notes
Tax on inbound investment—Romania—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to tax on inbound investment in Romania...
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15th May
Practice notes
The UK tax treatment of dual contracts [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.One of the features of the UK...
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Produced in partnership with Darren Oswick of Simmons & Simmons 15th May
Practice notes
Taxation of hedge funds—hedge fund managers and the management structureWhen considering the fund management structure for a hedge fund, the structure...
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Produced in partnership with James McCredie and Alicia Thomas of Macfarlanes LLP 15th May

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