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CORPORATE TAXES


The Companies Act 2006 (Distributions of Insurance Companies) Regulations, SI 2016/1194, set out a new methodology for insurers to segregate life and non-life business, following the implementation of the EU ‘Solvency 2’ directive, to ensure that firms only make distributions out of realised prof

Mark Middleditch (Allen & Overy) examines the themes that have dominated 2016 for the City, including the anti-hybrid rules brought on by the UK’s enthusiasm for BEPS, and looks at 2016’s case law, which shows that HMRC continues its run of success in defeating tax avoidance schemes.

After last week’s stunning result in the US presidential election, the likelihood of comprehensive tax reform has increased dramatically. Donald L Korb and Andrew Solomon (Sullivan & Cromwell) consider the headline proposals and their prospects.
 

The OTS wants to know what companies and their advisers find difficult or time consuming about corporation tax, says its tax director John Whiting.

New rules enacted in Finance Act 2016 were effective from 5 July in relation to the income tax and corporation tax treatment of transactions concerning land in the UK. Although the rules apply to structures involving offshore developers and much...

The Office of Tax Simplification (OTS) has published a progress report on its current review of the corporation tax computation, for which terms of reference were published in May 2016.

The Financial Reporting Council (FRC) has published its report on a review of certain aspects of tax reporting in company annual reports and accounts, finding evidence of improvements in the transparency of tax disclosures included in strategic reports and effective tax rate reconciliations.

Sarah Lane and Jack Lewis (FTI Consulting) look at the background and the effect of the proposals using worked hypothetical examples.
 
Paul Howard (Gabelle) provides this month’s update examining the most significant recent tax developments affecting SMEs.
 
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.
 
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