WITHHOLDING-TAX

The final CIS regulations and HMRC guidance don’t appear to measure up to the original policy ambition of removing ‘the majority of landlord to tenant payments from the scheme’, writes Kyle Rainsford (Travers Smith).

Mike Lane

Zoe Andrews

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) examines the Court of Appeal decisions in BlackRock and Hargreaves Property, HMRC’s updated guidance on capital-raising arrangements and share exchange clearances, and the OECD’s consolidated commentary on the GloBE model rules.

Robert Langston

Robert Langston (Saffery) provides a practical case study on the operation of the corporate interest restriction where related party guarantees and withholding tax issues are involved.

Tim Sarson

The Advocate General’s opinion on the CFC Finco exemption state aid case, new US regulations and an update on Pillar Two are among the developments in this month’s review by Tim Sarson (KPMG).

Interest on recurring loans constituted yearly interest and UK to UK exemption did not apply.

Ben Jones, Deepesh Upadhyay, Benjamin Shem-Tov

Ben Jones, Deepesh Upadhyay and Benjamin Shem-Tov (Eversheds Sutherland) examine the increasing use of side fund letters in a private investment funds context and the associated most favoured nations process.

Artem Vasyutin

Sophie Hatton

As a territorial tax regime, the UK has a number of benefits, which have only increased over the last two decades, write Artem Vasyutin and Sophie Hatton (Deloitte).

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.

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.