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The focus of today's Budget was on reducing the budget deficit and building a stronger economy. With little room for manoeuvre, the focus was on a few issues which the Government regards as key to achieving this.  The Government reiterated its desire...

The European Commission today published its detailed proposal for an EU Financial Transaction Tax to be implemented under the "enhanced cooperation procedure" across France, Germany, and nine other EU Member States. If adopted, most equity, debt and...

Yesterday's ECOFIN meeting resolved to use the "enhanced cooperation procedure" to implement an EU financial transaction tax across France, Germany, and the nine other EU Member States that wish to do so. Most equity, debt and derivative transactions...

Since FATCA was enacted in 2010 there has been widespread concern at the cost of compliance. But many have also been concerned at the two key legal risks FATCA creates – the risk that compliance contravenes local law and the risk that FATCA results in unexpected...

FATCA – the rules originally introduced as the Foreign Account Tax Compliance Act – imposes US withholding taxes and significant compliance obligations on banks and financial institutions worldwide.  Many lending, derivative and capital market...

There is a good case that the government's proposed CFC rules are not fully compliant with EU law. The draft legislation lacks an exemption for companies which are actually established and conducting genuine economic activities in other EEA Member States....

FATCA – the Foreign Account Tax Compliance Act – imposes US withholding taxes and compliance obligations on banks and financial institutions worldwide. Since it was enacted in 2010, FATCA has been widely criticised as over-broad and unworkable –...

Businesses are keen to operate in the UK and individuals want to live here, but both are constantly being blandished by other jurisdictions with tax breaks of one kind or another. The UK has rightly responded by introducing incentives to make the UK a competitive...

Unfortunately the Aaronson Report does not give examples of arrangements that would be caught by the GAAR, perhaps because most aggressive tax planning has failed in the courts recently. Even where taxpayers have steered a course through the maze of anti-avoidance...

The trading exemption in ss 371HE–371HK is not as userfriendly as one would hope.