WITHHOLDING-TAX

Mike Lane

The consultation on hedging risks for future share transactions and the FTT decision in Hargreaves are some of the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Dominic Stuttaford

Sofia Casselbrant

Dominic Stuttaford and Sofia Casselbrant (Norton Rose Fulbright) consider the FTT’s decision in Hargreaves and its implications for the UK withholding tax regime.

Elena Rowlands Emily Clark Ian Zeider

Emily Clark, Elena Rowlands and Ian Zeider (Travers Smith) give an overview of, and their verdict on, the QAHC legislation in the Finance Bill.

Tim Sarson

Progress on BEPS 2.0, the EU’s public CBCR directive and plans for a new EU withholding tax system are among recent developments examined by Tim Sarson (KPMG).

Gregory Price

Sarah Ling

BEPS 2.0 and ATAD 3 represent the latest challenge to the tax status of holding companies, renewing focus on issues of substance and withholding taxes, write Gregory Price and Sarah Ling (Macfarlanes).

James McCredie

James McCredie (Macfarlanes) reviews a hugely welcome new regime, but explains there are still some ‘shoot in foot’ opportunities that it is to be hoped the government and HMRC will resist.

Paul Pritchard

Football may not be coming home, but there is always tax to consider. Paul Pritchard (FTI Consulting) reviews the tax issues on player transfers, including the reinvestment relief on players, employment tax issues with buyout and the withholding of tax on image rights payments.

Claire Cross

David Corker

The ‘revenue rule’ is a longstanding legal principle that the courts of one country will not enforce the tax laws of another country. It was recently tested in the High Court, as David Corker and Claire Cross (Corker Binning) report.