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Withholding tax
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Withholding tax
WITHHOLDING-TAX
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
Elena Rowlands
Ian Zeider
Emily Clark
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).
The UK asset holding company regime: a quacking idea!
James McCredie
James McCredie (Macfarlanes) reviews a hugely welcome new regime, but
explains there are still some ‘shoot in foot’ opportunities that it is to be hoped
the government and HMRC will resist.
Football player transfers
Paul Pritchard
Football may not be coming home, but there is always tax to consider. Paul Pritchard (FTI Consulting) reviews the tax issues on player transfers, including the reinvestment relief on players, employment tax issues with buyout and the withholding of tax on image rights payments.
SKAT and the revenue rule
David Corker
Claire Cross
The ‘revenue rule’ is a longstanding legal principle that the courts of one country
will not enforce the tax laws of another country. It was recently tested in the
High Court, as David Corker and Claire Cross (Corker Binning) report.
Property investment: some recent developments
Simon Rose
Kitty Swanson
Kitty Swanson and Simon Rose (Mayer Brown) consider some important tax issues affecting investors in UK real estate.
The taxation of receivables finance transactions
Matthew Mortimer
Emma Noehrbass
Matthew Mortimer and Emma Noehrbass (Mayer Brown) consider some
important tax treatments that can apply to receivables finance transactions.
International tax and treasury issues in 2021
Andrew Cotterill
John Webb
Mairead Murphy
Interest deductibility, foreign exchange, withholding taxes... John Webb,
Andrew Cotterill and Mairead Murphy (PwC) review the key UK tax
considerations for financing transactions and global treasury functions.
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6
EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
Test-Chancellor outlines financial services strategy
Test16/09/2025-Chancellor outlines financial services strategy
Test16/09/2025-Chancellor outlines financial services strategyAA
HMRC manual changes: 18 July 2025
Chancellor outlines financial services strategy
CASES
Read all
Abbotsford Property Group Ltd and another v Revenue Scotland
R (oao Thomas Holdings Ltd and others) v HMRC
G Stenhouse and another v HMRC
Other cases that caught our eye: 18 July 2025
B D’Angelin v HMRC
IN BRIEF
Read all
HMRC’s approach to wealthy individuals
There’s only one POEM
Discovery assessments: agents
Standish v Standish
Section 899 compromise shifts international tax landscape
MOST READ
Read all
‘Legislation Day’ date announced
G Haworth and others v HMRC
One Big Beautiful Bill Act enacted
Abbotsford Property Group Ltd and another v Revenue Scotland
One minute with... Charlie Friend