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Home
Withholding tax
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Withholding tax
WITHHOLDING-TAX
Beneficial entitlement in Hargreaves: is Indofood now part of UK domestic law?
Dominic Robertson
The Upper Tribunal in
Hargreaves
effectively seeks to import the Indofood concept of beneficial entitlement into domestic law. Dominic Robertson (Slaughter and May) examines the practical uncertainties this creates and questions whether the decision was correctly decided.
Withholding tax: Hargreave-ances
Deepesh Upadhyay
Sean Wright
Deepesh Upadhyay and Sean Wright (Eversheds Sutherland) review the Upper Tribunal’s decision in Hargreaves which considers withholding tax and interest payments.
Investment into and expansion within the UK: acquisition planning
Helena Kanczula
When structuring a UK acquisition, there are a myriad of tax issues to
consider, as Helena Kanczula (BKL) explains.
Tax and the City review for April 2022
Mike Lane
Zoe Andrews
The Supreme Court decision in
NCL Investments Ltd
and the Court of Appeal decision in
Skatteforvaltningen
are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Dicey Rule 3: the Court of Appeal’s decision in Skat v Solo
Philip Baker QC
Dilpreet K. Dhanoa
The Court of Appeal has upheld SKAT’s claims. Philip Baker QC and Dilpreet K. Dhanoa (Field Court Tax Chambers) analyse whether, from a legal and international tax perspective, this was the correct decision.
Tax and the City review for January 2022
Mike Lane
Zoe Andrews
The consultation on hedging risks for future share transactions and the FTT
decision in
Hargreaves
are some of the recent developments reviewed by
Mike Lane and Zoe Andrews (Slaughter and May).
Hargreaves: withholding tax on rollover funding under scrutiny
Dominic Stuttaford
Sofia Casselbrant
Dominic Stuttaford and Sofia Casselbrant (Norton Rose Fulbright) consider the FTT’s decision in
Hargreaves
and its implications for the UK withholding tax regime.
The UK’s new qualifying asset holding company regime
Emily Clark
,
Elena Rowlands
,
Ian Zeider
Emily Clark, Elena Rowlands and Ian Zeider (Travers Smith) give an overview of, and their verdict on, the QAHC legislation in the Finance Bill.
International review for October 2021
Tim Sarson
Progress on BEPS 2.0, the EU’s public CBCR directive and plans for a new EU withholding tax system are among recent developments examined by Tim Sarson (KPMG).
The war on holding companies and the return of withholding taxes
Gregory Price
Sarah Ling
BEPS 2.0 and ATAD 3 represent the latest challenge to the tax status of holding companies, renewing focus on issues of substance and withholding taxes, write Gregory Price and Sarah Ling (Macfarlanes).
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EDITOR'S PICK
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
1 /7
What happens at a tribunal hearing?
Anne Redston
2 /7
Schedule 36: a stitch in time
Keith Gordon
3 /7
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
,
Cécile Perrault
4 /7
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
,
Rhiannon Kinghall Were
5 /7
Tax Administration and Maintenance Day: report
6 /7
Pension planning after the Budget
Mike J Haynes
7 /7
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
What happens at a tribunal hearing?
Anne Redston
Schedule 36: a stitch in time
Keith Gordon
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
,
Cécile Perrault
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
,
Rhiannon Kinghall Were
Tax Administration and Maintenance Day: report
Pension planning after the Budget
Mike J Haynes
NEWS
Read all
Treasury Committee calls for systematic review of tax reliefs
NICs investment zone reliefs for employers
R&D claim requirements confirmed
New transfer pricing records requirements
HMRC issues clarifications on SBAs
CASES
Read all
M R Currell Ltd v HMRC
Sonder Europe Ltd v HMRC
TP v Administration de l’Enregistrement, des Domaines et de la TVA
Ebuyer (UK) Ltd v HMRC
Other cases that caught our eye: 28 July 2023
IN BRIEF
Read all
Self’s assessment: Inheritance tax
When does a payment constitute a distribution?
OECD inclusive framework publishes outcome statement on Pillar One and Pillar Two
Legislation day: practitioners' views
Challenging information notices
MOST READ
Read all