CORPORATE TAXES

Jisun Choi

Moshe Spinowitz and Jisun Choi (Skadden) assess the growing attractions of a US parent company following tax reforms and the Side-by-Side package, explaining the trade-offs and complexities involved in relocating.

Paul Rattew

John Endacott

John Endacott and Paul Rattew (PKF Francis Clark) examine proposed reforms to company distributions and the taxation of value extracted by private shareholders.

Joe Robinson

Harvey Innocent

Joe Robinson and Harvey Innocent (Macfarlanes) explain how LLP members may defer gains when transferring their interests to a company, while highlighting additional complications for corporate members and goodwill.

Richard Jeens

Stephanie Mullins

Stephanie Mullins and Richard Jeens (Slaughter and May) explain how to take control of Sch 36 notices by engaging early with HMRC to narrow scope and responding strategically.

Oliver Walker

Ellie Marques

Check in, but can you check out? Oliver Walker and Ellie Marques (Weil, Gotshal & Manges) explain why companies considering moving to the UK need to think carefully about the UK tax ramifications.

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the HFFX decision on LLP deferred remuneration, HMRC’s distributions consultation, the Barclays case on VAT grouping and the credit-management exemption in securitisations.

Ros Martin

Consultant Ros Martin provides an overview of this year’s Finance Act, including reforms to income tax and inheritance tax, the recast carried interest regime, changes to capital allowances and venture capital schemes, and expanded compliance and anti-avoidance provisions.

Jenny Doak

Jenny Doak (Paul Hastings) contrasts a year of relative domestic stability with international upheaval.

Paul Rogerson

No changes were announced in the Budget to the rates of ring fence corporation tax, supplementary charge to corporation tax or the energy profits levy (EPL). There was no announcement on any change to EPL and therefore this will remain in place until...