Results 1-10 of 27
29 October 2018
In his October 2018 Budget speech, the UK Chancellor announced a radical new Digital Services Tax ("DST") on digital platforms that derive their economic value from the participation of UK users. The DST significantly departs from the traditional...
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...
Withholding Tax Revolution? The Effect of the BEPS Multilateral Convention on Cross-Border Debt and Equity Investments
8 June 2017
68 countries signed the BEPS multilateral convention on Wednesday 7 June. Its effect is to amend the hundreds of double tax treaties between those countries to introduce new anti-avoidance rules. After years of uncertainty we finally know which countries...
HMRC Double Taxation Treaty Passport Scheme: what the 2017 changes mean for borrowers, lenders and the UK loan market
7 April 2017
The Double Taxation Treaty Passport (DTTP) Scheme is critical for funds and other non-UK lenders active in the UK loan market. However, the DTTP Scheme has historically only applied where borrower and lender are both corporate entities. Following a recent consultation,...
20 October 2016
In this Corporate Treasury Update, Clifford Chance explores some of the major market developments in 2016 and how they impact treasury functions. The update briefly considers the CBPS, MAR, BEPS tax implications, cash management, Euro clearing, negative interest...
17 October 2016
On October 13, 2016, the Treasury and the IRS issued regulations that make it harder for a non-US parent company with US subsidiaries to use intercompany debt to strip taxable earnings out of those subsidiaries.
22 July 2016
The European Court of Justice (ECJ) has recently ruled in the case of Aspiro (C-40/15) that insurance claims handling services outsourced to third party service providers do not fall within the insurance VAT exemption. The ECJ held that the services could only...
24 June 2016
On 23 June 2016 the UK voted to leave the European Union. Whilst many of the terms of exit are hard to anticipate, there are a number of predictable adverse effects for which preparations can be made. This briefing outlines some mitigating steps that UK and EU...
6 April 2016
On Monday, April 4, 2016, the Treasury and the IRS issued temporary and proposed regulations which make it harder to successfully complete an inversion transaction, and to reduce an inverted US company's taxes through the use of intercompany debt.