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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
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
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

Practice notes
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 15th May
Practice notes
CFC rules—chapter 9 finance company exemptionsSTOP PRESS:With effect from 17 December 2020, Royal Assent of the Taxation (Post-transition Period) Act...
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15th May
Practice notes
CFC rules—definition of legal, economic and accounting control This Practice Note deals with the controlled foreign company (CFC) rules that apply...
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15th May
Practice notes
Foreign branch exemption—anti-diversion before 1 January 2013 [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This note...
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15th May
Practice notes
Tie breakers—when tax treaties impact on the UK tax residence of companiesEach jurisdiction applies its own domestic law test to determine when a...
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15th May
Practice notes
Directive for administrative cooperation in the field of taxation (DAC)—FAQsIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 15th 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 15th May
Practice notes
Taxation of hedge funds—what is a hedge fund?Although there is no specific definition of the term ‘hedge fund’, there are a number of characteristics...
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Produced in partnership with James McCredie and Alicia Thomas of Macfarlanes LLP 15th May
Practice notes
Taxation of hedge funds—structure of the hedge fund vehicleThis Practice Note looks at the typical legal structure of a hedge fund vehicle.For what...
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Produced in partnership with James McCredie and Alicia Thomas of Macfarlanes LLP 15th May
Practice notes
US: Foreign Account Tax Compliance Act (FATCA)—what is FATCA?On 18 March 2010, the Hiring Incentives to Restore Employment Act (the HIRE Act) was...
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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
Tax—FATCA trackerThis tax 'tracker' tool displays the current status of both US FATCA and UK FATCA intergovernmental agreements (IGA).The tracker is...
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15th May
Practice notes
Non-discrimination in double tax treatiesIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation...
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Produced in partnership with David Klass of Hunton Andrews Kurth 15th May
Practice notes
CFC rules—assumed taxable total profits and assumed total profitsThis Practice Note deals with the controlled foreign company (CFC) rules that apply...
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15th May
Practice notes
Tax on inbound investment—Austria—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to tax on inbound investment in Austria...
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15th May
Practice notes
Tax controversy—Netherlands—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to tax controversy in Netherlands published as part...
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15th May
Practice notes
Brexit and tax—the continued application of EU lawThis Practice Note is about the extent to which EU law continues to apply to the UK’s tax rules...
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15th May
Practice notes
VAT—buying goods in the EUIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 15th May
Practice notes
VAT treatment of intermediaries and agentsIP 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 Fuszard of Sagars Accountants Ltd 15th May
Practice notes
A history of EU law and thin capitalisation and transfer pricing regimes [Archived]ARCHIVED: This Practice Note has been archived and is not...
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Produced in partnership with Kelly Stricklin-Coutinho 15th May
Practice notes
Administration of UK withholding tax on yearly interest and other types of incomeThis Practice Note outlines the key administrative obligations,...
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15th May

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