Christopher Morgan (KPMG) provides an update of recent developments, including: the OECD’s BEPS project; the CJEU decision in the EC’s challenge to UK cross-border relief; the Prudential Assurance case; the EC investigation into Belgium’s excess profit rulings; and news from Ireland and the US.
The government is progressing with measures to align the national insurance and income tax liabilities of employment-related securities (ERS) held by internationally mobile employees (IMEs). Sarah McMaster (Baker & McKenzie) assesses the practical implications of the proposals.
The Office of Tax Simplification (OTS) has published its third and possibly final report on the subject of the taxation of partnerships for smaller unrepresented businesses that are trading in an unincorporated form. Mark Waddilove (Baker Tilly) which responded to the consultation, assesses the report.
What does or doesn’t constitute a transfer of a going concern (TOGC)? Timothy Jarvis (Squire Patton Boggs) examines the Upper Tribunal’s decision in the Royal College of Paediatrics VAT case.
While the much-anticipated decision in Project Blue is unsurprising, the decision raises some points of wider interest, including because HMRC prevailed by using FA 2003 s 75A, the SDLT anti-avoidance rule. Michael Thomas (Gray’s Inn Tax Chambers) reports
Andrew Goldstone and Charlie Sosna (Mishcon de Reya) round up the latest private client news, including: the remittance basis charge consultation; a report on tax incentives for art; Hutchings; and BiGDUG Limited Remuneration Trust (from Guernsey)
Martin Zetter (Macfarlanes) summarises recent developments, including the latest from the OECD’s BEPS project, as well as updates from the UK, Spain, the US and Singapore
Helen Adams and Frank Goldberg (BDO) provide a refresher guide to HMRC’s wide range of powers to collect tax debts
President Obama has proposed a levy for US corporations on profits located abroad, which are not repatriated to the US. Kristin Konschnik and Mitchell R. Kops (Withers) consider the proposals and what effect they may have in practice
The Upper Tribunal’s decision to uphold the First-tier Tribunal's ruling in Astral creates opportunity, but also uncertainty regarding what counts as the construction of a new building. Graham Elliott (Withers) examines the issues