In the Irish Bank case the Court of Appeal agrees with the Upper Tribunal that attribution of notional capital to a UK PE of an Irish bank (rather than looking at actual capital) is compatible with the UK/Ireland double tax convention. A new tax the economic crime levy is intended to raise £100m a year from 2022/23 and it is going to be payable by the AML-regulated sector subject to thresholds and exemptions to be decided. Lessons can be learnt from recent High Court decisions involving M&A disputes: Dodika emphasises the necessity for a buyer to comply strictly with any contractual notice provisions when bringing a claim against a seller in respect of a tax liability; whereas Axa is a reminder of documenting parties’ intentions clearly. Responses to the consultation on the notification of uncertain tax treatment question whether such a measure is necessary and if...
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In the Irish Bank case the Court of Appeal agrees with the Upper Tribunal that attribution of notional capital to a UK PE of an Irish bank (rather than looking at actual capital) is compatible with the UK/Ireland double tax convention. A new tax the economic crime levy is intended to raise £100m a year from 2022/23 and it is going to be payable by the AML-regulated sector subject to thresholds and exemptions to be decided. Lessons can be learnt from recent High Court decisions involving M&A disputes: Dodika emphasises the necessity for a buyer to comply strictly with any contractual notice provisions when bringing a claim against a seller in respect of a tax liability; whereas Axa is a reminder of documenting parties’ intentions clearly. Responses to the consultation on the notification of uncertain tax treatment question whether such a measure is necessary and if...
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