Several recent case decisions in the private client arena, including the correct interpretation of the ‘place of effective management’ tie-breaker test, are examined by Edward Reed and Ross Pizzuti-Davidson (Macfarlanes).
Jill Gatehouse, Josh Critchlow and Alison Dickie (Freshfields Bruckhaus Deringer) explore some of the interesting questions about the tax consequences of the proposed regime.
Jenni Bullivant, Creina Kane and Aaron Mehta (PwC) reflect on the host of international tax issues and complexities associated with international holding structures as a consequence of the continually changing external landscape.
Ashley Greenbank and Penny Van den Brande (Macfarlanes) consider the UK tax consequences for businesses considering moving assets or functions out of the UK, whether by a change of residence of a UK company, the insertion of a new, non-UK, holding company or the relocation of specific assets and functions
Julian Feiner (Clifford Chance) discusses the taxpayers' resounding victory at the Upper Tribunal in the company residency case of Development Securities plc and others v HMRC.