Results 1-10 of 55
£1 billion+ state aid to be recovered from UK corporates with finance subsidiaries - How should businesses react?
2 April 2019
The Commission has now issued its final decision in its State aid investigation into the Group Finance Exemptions from the UK's controlled foreign companies (CFC) rules, concluding that the exemptions constitute unlawful State aid. UK parented groups which...
15 January 2019
The PDCF is stated to be targeted at taxpayers who have adopted cross-border arrangements which divert profits from the UK based upon inaccurate facts or the incorrect application of OECD transfer pricing guidelines. Those taxpayers should, HMRC believes, be subject...
29 October 2018
In his October 2018 Budget speech, the UK Chancellor announced the replacement of UK Regulations governing regulatory capital instruments with new tax rules for all hybrid capital instruments. In this briefing we examine the background, State Aid and MREL/TLAC...
7 June 2018
New EU rules - commonly known as "DAC 6" - under the Directive on Administrative Cooperation require taxpayers and intermediaries to report a wide range of transactions to their home tax authorities. In some cases these are transactions that are tax-motivated....
21 December 2017
On December 20, 2017, Congress voted to enact the most sweeping US tax reform bill in decades. The Tax Cuts and Jobs Act will reduce business tax rates and revamp the US international tax system. While the President may not sign the Act until January 2018,...
New UK taxes on offshore IP structures - The impact on traditional and digital businesses - UK Budget 2017
23 November 2017
The Government's Budget was announced by the Chancellor on 22 November 2017. It includes a series of proposals attacking offshore IP structures. The main targets are foreign digital businesses, but all businesses that employ offshore IP structures will be...
20 November 2017
The UK’s current CFC rules were created in the light of decisions of the CJEU and EFTA Court, which suggested that in most cases involving EEA subsidiaries it will be unlawful for the then existing CFC rules to apply at all. However, the European Commission...
1 November 2017
The European Commission has opened an in-depth State aid probe into the group financing exemption under the UK's Controlled Foreign Companies (CFC) rules. An adverse finding at the end of the investigation, even if after the date of Brexit, could lead to the...
Criminal Finances Act 2017: Starting gun fired for financial crime changes - New tax offences enter into force
29 September 2017
On 30 September, new corporate offences in relation to failure to prevent the facilitation of tax evasion will enter into force. However, the Criminal Finances Act 2017, which introduces them, also contains a raft of other changes to UK financial crime frameworks....
Labour's proposed UK financial transaction tax: What it means for investors, institutions and businesses
18 July 2017
The Labour Party has announced a plan to expand the existing UK stamp duty into a broader financial transaction tax. Stamp duty currently applies in practice only to UK equities. Labour's proposed tax would cover all equities and debt securities, if there...