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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
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 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
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
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
Tax on inbound investment—Lithuania—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to tax on inbound investment in Lithuania...
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15th May
Practice notes
Tax controversy—Norway—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to tax controversy in Norway published as part of the...
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15th May
Practice notes
Taxation of offshore funds—requirements of the reporting funds regimeUK investors in ‘reporting’ offshore funds are charged to tax on their share of...
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Produced in partnership with Michael Alliston 15th May
Practice notes
Taxation of hedge funds—trading in the UK and the investment manager exemption (IME)A hedge fund will typically be established as a non-UK company...
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Produced in partnership with James McCredie and Alicia Thomas of Macfarlanes LLP 15th May
Practice notes
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 15th May
Practice notes
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 15th May
Practice notes
Exemptions and reliefs from UK withholding tax on yearly interestUnless an exemption or relief applies, payments of:•yearly interest (or amounts that...
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15th May
Practice notes
Unilateral relief for foreign taxUnilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being...
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15th May
Practice notes
Transfer pricing—Brazil—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to transfer pricing in Brazil published as part of the...
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15th May
Practice notes
Tax considerations for a UK bank lender when lending to an overseas borrowerIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the...
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Produced in partnership with Ben Jones and Deepesh Upadhyay of Eversheds Sutherland LLP and Tim Shaw of Ensors Accountants LLP 15th May
Practice notes
VAT—importing goods from outside the EUIP 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 John Fuszard of Sagars Accountants Ltd 15th May
Practice notes
Foreign branch exemption—foreign permanent establishments amountAs explained in Practice Note: Foreign branch exemption—structure of the foreign...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 15th May
Practice notes
What is a UK permanent establishment?Coronavirus (COVID-19): For information on the inadvertent creation of permanent establishments as a result of...
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15th May
Practice notes
Transfer pricing—Germany—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to transfer pricing in Germany published as part of...
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15th May
Practice notes
Tax controversy—Brazil—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to tax controversy in Brazil published as part of the...
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15th May
Practice notes
Tax on inbound investment—United Kingdom—Q&A guideThis Practice Note contains a jurisdiction-specific Q&A guide to tax on inbound investment in United...
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15th May
Practice notes
Royalties articles 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
Interaction of EU law and direct taxThis Practice Note is about the interaction between EU law and the direct tax rules of EU Member States, and in...
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Produced in partnership with Etienne Wong of Old Square Tax Chambers 15th May
Practice notes
CFC rules—chapter 5 non-trade finance gatewayThis Practice Note deals with the controlled foreign company (CFC) rules that apply for accounting...
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15th May
Practice notes
Old CFC rules—definition of a CFC: company, accounting period and lower level of taxation [Archived]ARCHIVED: This Practice Note has been archived and...
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15th May

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