TAX-TREATMENT

Alice Martin Elena Dunn Carolyn Steppler

Alice Martin, Elena Dunn and Carolyn Steppler (Charles Russell Speechlys) consider the UK tax and practical risks arising from offshore trust loans, including unexpected IHT exposure, settlor charges and the consequences of irrecoverable debts.

Yousuf Chughtai

Jack Prytherch

Jack Prytherch and Yousuf Chughtai (Osborne Clarke) assess HMRC’s plans to widen the UTT regime and the practical implications for taxpayers.

Lika Jatoeva

Nigel Doran

Nigel Doran and Lika Jatoeva (Macfarlanes) review HMRC’s updated guidance on deferred remuneration for internationally mobile employees and consider the resulting risks of double taxation and NICs mismatches.

Sophie Dworetzsky

Sophie Dworetzsky (Lombard Odier) reviews recent developments including rejected calls to extend IHT payment deadlines, proposed expansion of the UTT regime to individuals and trusts, and practical issues arising from pensions, SDLT and trust changes.

Mike Lane

Zoe Andrews

Mike Lane and Zoe Andrews (Slaughter and May) consider the Court of Appeal’s purposive approach to the notional company fiction in Muller, HMRC’s consultation on extending the Uncertain Tax Treatment regime, and the proposed UK corporate re-domiciliation regime.

Eloise Walker

When should damages be calculated net of tax? Eloise Walker (Pinsent Masons) revisits the Gourley principle and its practical implications for commercial disputes.

Finn Halton

Gregory Price

HMRC’s new service could provide a valuable focused engagement channel for major investments, write Gregory Price and Finn Halton (Macfarlanes).

Kate Pearson Helen Coward Annabelle Trotter

The tax insurance market has grown significantly. Helen Coward (Simmons & Simmons) speaks with Annabelle Trotter and Kate Pearson (Howden) about how it is now used across an increasingly broad range of transactions.

Tamar Ruiz

Matthew Mortimer

Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine key recent changes to the UK taxation of foreign exchange gains and losses.

Ceinwen Rees

Frankie Beetham

The newly reformed tax on carried interest will subject carried interest to the payments on account regime. Ceinwen Rees and Frankie Beetham (Kirkland & Ellis) set out some of the key practical considerations.

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