CORPORATE TAXES

With the UK’s continuing attractiveness as a holding company tax jurisdiction, Jonathan Cooklin and Dominic Foulkes (Davis Polk) consider the scope of technical UK tax issues that have a direct bearing on the drafting of merger agreements and related documents which implement these transactions.

HMRC is consulting until 19 October 2016 on limiting the range of benefits that attract income tax and NICs advantages when provided as part of salary sacrifice arrangements.

HMRC is consulting until 5 October 2016 on a first draft of Finance Bill 2017 legislation for the changes to the treatment of termination payments announced at Budget 2016. These changes will take effect from April 2018.

HMRC is consulting until 5 October 2016 on a first draft of Finance Bill 2017 legislation introducing changes to tackle disguised remuneration avoidance schemes, as set out in the technical note published at Budget 2016.

Kevin Offer

Kevin Offer (Gabelle) reviews the case of English Holdings Ltd v HMRC, where corporate losses were claimed against income.

Maya Forstater

New rules will require large UK companies to publish their tax strategies. Researcher Maya Forstater reviews the 61 statements already published by FTSE 100 companies.

Ashley Greenbank

Ashley Greenbank (Macfarlanes) considers the proposals for the introduction of further adjustments to counteract the financial benefits of cash flows arising from non-arm’s length transfer pricing.

Mark Middleditch

Mark Middleditch (Allen & Overy) reviews recent developments affecting the City.

Gideon Sanitt

Corporates are facing the regulatory scrutiny once reserved for banks. Gideon Sanitt (Macfarlanes) considers the treatment of the costs of such investigations.

Joseph Goldman

Anthony Whall

The US Treasury recently issued new regulations to deter corporate ‘inversions’, where a US parented company and a non-US company combine and locate the tax residence of the merged company in a non-US jurisdiction. Joseph Goldman and Anthony Whall (Jones Day) review their impact.

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