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WITHHOLDING TAXES


Brin Rajathurai and Robert Jones (Freshfields Bruckhaus Deringer) review a useful exemption that is sometimes overlooked.
Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures. 
Card image Paul Radcliffe, David Wren, Reinhart Devisscher
Paul Radcliffe, David Wren and Reinhart Devisscher (EY) consider the next steps for the EU to develop this model, and some key areas which may need to be contemplated in light of the European Commission’s upcoming consultation.
While the UK’s new digital services tax hogged the limelight in the recent Budget, much less attention was paid to the fact that the proposed extension of withholding tax on royalties paid to tax havens (announced at the previous Budget) was...
Paul Shaw and Paul Williams (Bryan Cave Leighton Paisner) examine a recent tribunal decision on the nature of annual payments and platform agreements.
 
Dominic Foulkes and Jonathan Cooklin (Davis Polk) consider some developments on the taxation of lending into UK acquisition finance structures.
 
The changes in the current Finance Bill will bring rather more intellectual property royalties into the scope of withholding tax, as Anne Fairpo (Temple Tax Chambers) explains.
 

OUR PICK

According to HMRC statistics released last week, HMRC recovered £1.1bn tax from transfer pricing enquiries during 2013/14, which HMRC said was double the tax take of the previous year.

The government announced a new exemption for withholding tax on private placements – a potentially important source of non-bank funding for UK businesses – at the Autumn Statement. James Hume (Slaughter and May) reports.

Heather Self considers the changes made to the Model Tax Convention (MTC) and what these updates mean in practice.

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