DOUBLE-TAXATION

Philip Baker KC (Field Court Tax Chambers) considers why existing rules struggle to tax cross-border services effectively and proposes an alternative solution.

Alex Ereira

Aron Joy

The carried interest reforms create substantial compliance burdens and may expose internationally mobile investment managers to double taxation, write Aron Joy and Alex Ereira (Weil, Gotshal & Manges).

Harriet Betteridge

Which pensions will be taxed? Who is responsible for reporting and paying the tax? What’s the impact on planning? Harriet Betteridge (Charles Russell Speechlys) examines some key questions surrounding the proposed legislation.

EBT was not remuneration

Klara Kronbergs

Edward Reed

In this month’s review, Edward Reed and Klara Kronbergs (Macfarlanes) consider some of the more nuanced aspects of the non-dom reforms, as well as some key tribunal decisions affecting private clients.

Robert Langston

Robert Langston (Saffery) explains why it is necessary to consider international tax principles, such as entity classification and transfer pricing, alongside the disguised investment management fee 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.

Oliver Marre

Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and its implications going forward.

Upper Tribunal finds FTT correctly tested place of effective management of trusts.

Sebastian Prichard Jones

Andrew Crozier

HMRC’s updated guidance on the treatment of profits arising within, and distributions from, US LLCs is unsatisfactory in a number of respects, write Sebastian Prichard Jones and Andrew Crozier (Macfarlanes).

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