WITHHOLDING-TAX

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.

Repayment of withholding tax: Skatteforvaltningen v Solo Capital Partners LLP [2025] EWHC 2364 (Comm) (2 October) is the long-awaited judgment in the case under which the Danish tax authorities are suing various individuals and firms in respect of...

Gemma Grunewald

In the first of a new series on the lifecycle of a transaction – from acquisition to operation and ultimate exit – Gemma Grunewald (DLA Piper) examines some of the key considerations for a buyer when structuring an acquisition.

Tamar Ruiz

Matthew Mortimer

Matthew Mortimer and Tamar Ruiz (Mayer Brown) provide an overview of the tax treatment of derivatives, repo and stock loan transactions for UK companies.

Ceinwen Rees

Serene Ho

Ceinwen Rees and Serene Ho (Kirkland & Ellis) explain why boilerplate clauses exist and why it’s important to check that they are included in the contract.

Zoe Andrews

Mike Lane

The decisions in JTI, Altrad and Burlington are examined in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

Reinhart Devisscher

Paul Radcliffe

After ten compromise texts and two years of political debate, agreement has finally been reached on new rules for EU withholding tax procedures. Paul Radcliffe and Reinhart Devisscher (EY) examine the detail and consider what’s next.

Dominic Robertson

Deepesh Upadhyay

Deepesh Upadhyay (Eversheds Sutherland) and Dominic Robertson (Slaughter and May) examine one of the most important withholding tax cases in years.

Kyle Rainsford

The final CIS regulations and HMRC guidance don’t appear to measure up to the original policy ambition of removing ‘the majority of landlord to tenant payments from the scheme’, writes Kyle Rainsford (Travers Smith).

Zoe Andrews

Mike Lane

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) examines the Court of Appeal decisions in BlackRock and Hargreaves Property, HMRC’s updated guidance on capital-raising arrangements and share exchange clearances, and the OECD’s consolidated commentary on the GloBE model rules.

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