INCOME-TAX

The Temporary Repatriation Facility could create significant tax savings for some. Alice Pearson (Mercer & Hole) highlights some practical considerations and areas of complexity.

Andrew Solomon

Aharon Friedman

Andrew Solomon and Aharon Friedman (Sullivan & Cromwell) review the One Big Beautiful Bill as a whole and look ahead to what’s next.

Bezhan Salehy

Damien Crossley

The draft Finance Bill provisions seek to address some of the issues for credit funds, write Bezhan Salehy and Damien Crossley (Macfarlanes).

Rebecca Rose Bezhan Salehy Elvira Colomer Fatjo

Bezhan Salehy, Rebecca Rose and Elvira Colomer Fatjo (Macfarlanes) take a practical look at UK interest withholding tax, highlighting common compliance pitfalls, HMRC’s approach and emerging complexities.

Taxpayers did not have a main purpose of obtaining an income tax advantage

Taxpayer liable to income tax on sums payable by overseas entities

TOAA applied on rent-free property settled in an offshore trust

Novation of director’s loan account

Payments to an EBT to avoid income tax and NICs did not have a ‘prohibited purpose’

Deemed income of settlor of offshore trusts outside the protected settlements regime

Go to page of 8