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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
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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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 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
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
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
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
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

Most recent International content

Practice notes
CFC rules—creditable taxThis Practice Note deals with the controlled foreign company (CFC) rules that apply for accounting periods of CFCs starting on...
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15th May
Practice notes
UK employment tax issues for cross-border employmentGiven the ever increasing global mobility of employees, employers could be regularly required to...
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Produced in partnership with Darren Oswick of Simmons & Simmons 15th May
Practice notes
Company migration or corporate inversion—how to change tax residence in practiceIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the...
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15th May
Practice notes
CFC rules—UK activities safe-harboursThis Practice Note deals with the controlled foreign company (CFC) rules that apply for accounting periods of...
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15th May
Practice notes
Old CFC rules—interests and relevant interests [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note deals...
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15th May
Practice notes
Tax on inbound investment—Chile—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to tax on inbound investment in Chile published...
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15th May
Practice notes
Tax controversy—India—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to tax controversy in India published as part of the...
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15th May
Practice notes
UK tax implications of overseas entity classification and distributions from overseas entitiesAn overseas entity may be characterised for UK tax...
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Produced in partnership with Robert Langston of Saffery Champness 15th May
Practice notes
What are the UK tax considerations for an overseas purchaser acquiring a UK business?A non-UK based purchaser of a UK business (or UK-headquartered...
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Produced in partnership with Ben Jones of Eversheds LLP and Tim Shaw of Blick Rothenberg Limited 15th May
Practice notes
Internationally mobile employees and employment-related securities (pre-6 April 2015) [Archived]ARCHIVED: This Practice Note has been archived and is...
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15th May
Practice notes
Applications for double tax treaty relief from UK withholding tax on interestFor more information on the other types of exemptions and reliefs from UK...
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15th May
Practice notes
Transfer pricing—United Kingdom—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to transfer pricing in United Kingdom published...
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15th May
Practice notes
Transfer pricing—Ireland—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to transfer pricing in Ireland published as part of...
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15th May
Practice notes
When do the UK transfer pricing rules apply?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 Simon Gough and Caroline Brown of Bird & Bird LLP 15th May
Practice notes
Exchange of information on 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 15th May
Practice notes
Old CFC rules—apportionment and tax charge [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note deals...
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15th May
Practice notes
Tax controversy—Switzerland—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to tax controversy in Switzerland published as part...
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15th May
Practice notes
Tax issues on financing an inbound investmentIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation...
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Produced in partnership with Jacob Gilkes of CMS 15th May
Practice notes
US: FATCA—foreign financial institutions (FFIs)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 John Narducci (Partner) and Stephen C Lessard (Associate) of Orrick, Herrington & Sutcliffe LLP 15th May
Practice notes
VAT treatment of electronically supplied servicesIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 15th May

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