Market leading insight for tax experts
Subscribe
Home
Saved articles
Viewed articles
Login
Logout
E-newsletter
Advertise
About us
Help
View online issue
BROWSE BY TOPIC
Corporate Taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect Taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International Taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private Business Taxes
OMBs
Partnerships
Private Client Taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real Estate Taxes
Property taxes
REITs
Stamp Taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
NEWS
CASES
IN BRIEF
ANALYSIS
ONE MINUTE WITH
PEOPLE & FIRMS
TRACKERS
AUTHORS
ISSUE ARCHIVE
BROWSE BY TOPIC
Corporate taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private business taxes
OMBs
Partnerships
Private client taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real estate taxes
Property taxes
REITs
Stamp taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
Subscribe
Home
Saved articles
Viewed articles
View virtual issue
View online issue
Login
Logout
E-newsletter
Advertise
About us
Help
News
Cases
In brief
Analysis
One Minute With
People & Firms
Trackers
Authors
Issue Archive
SEARCH
Home
Cross border
Home
Cross border
CROSS BORDER
Deferred remuneration: HMRC update their guidance on cross-border tax and NICs
Lika Jatoeva
Nigel Doran
Nigel Doran and Lika Jatoeva (Macfarlanes) review HMRC’s updated
guidance on deferred remuneration for internationally mobile employees and
consider the resulting risks of double taxation and NICs mismatches.
Tax and the private capital sector in 2026: three key issues
Tom Margesson
Elena Rowlands
Ian Zeider
Elena Rowlands, Tom Margesson and Ian Zeider (Travers Smith) take stock
of current developments.
From adversaries to agreement: can ADR unlock tax disputes around the world?
Liesl Fichardt
Emily Au
For cross-border disputes, there remains untapped potential for ADR to
resolve the waiting lists of cases in need of resolution, write Liesl Fichardt and
Emily Au (Quinn Emanuel).
Tax and the City review for March 2025
Mike Lane
Zoe Andrews
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
covers the decisions in
Lloyds Asset Leasing
and
Royal Bank of Canada
, as well
as HMRC’s plans to update guidance on the salaried member rules.
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Gerald Montagu (Gide Loyrette Nouel) examines the First-tier Tribunal
decision in
Lloyds Asset Leasing Ltd
.
Towards a common European withholding framework
Paul Radcliffe
Reinhart Devisscher
David Wren
Paul Radcliffe, David Wren and Reinhart Devisscher (EY) consider the next steps for the EU to develop this model, and some key areas which may need to be contemplated in light of the European Commission’s upcoming consultation.
EU freedoms in cross-border transactions
Dominic Stuttaford
Greg Branagan
Two recent decisions have sought to clarify the extent to which the EU freedom of establishment and of the movement of capital were restricted in light of various UK legislative provisions dealing with cross-border transactions and/or operations, as Dominic Stuttaford and Greg Branagan (Norton Rose Fulbright) explain.
DAC 6 update: UK narrows scope of mandatory reporting
Avi Kaye
Sandy Bhogal
Sandy Bhogal and Avi Kaye (Gibson, Dunn & Crutcher) explain the extent to which the UK government has curtailed existing reporting obligations.
Cross-border remote workers: PAYE issues
Sarah Hewson
Steve Wade
Sarah Hewson and Steve Wade (EY) examine PAYE obligations and how any UK employment tax risks can be mitigated.
How to choose your holding company location
Sara Luder
Charles Osborne
Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.
Go to page
of
36
EDITOR'S PICK
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
1 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
2 /7
The new Securities Transfer Tax: business as usual?
Georgina West
3 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
4 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
5 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
6 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
7 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
NEWS
Read all
CGT liabilities rise 89% to record £24.2bn
Pubs and hotels business rates: methodology call for evidence
Technical Note 2 for IHT on pensions
CIOT outlines support for extension of VAT online marketplace rules
VAT relief could remove barriers to social housing
CASES
Read all
Knights Developments Ltd v HMRC
A Pontin and others v HMRC
AXA Insurance UK plc and another v HMRC and another
HMRC v G Quillan
Perenco UK Ltd v HMRC
IN BRIEF
Read all
Sanctionable conduct
The end of offshore execution on secondary transactions
Tax adviser registration: deferral for investment managers
When is a trustee not a trustee?
Funding the business
MOST READ
Read all
Property 118 Ltd and another v HMRC
The end of offshore execution on secondary transactions
Perenco UK Ltd v HMRC
Knights Developments Ltd v HMRC
The 2026 loan charge settlement scheme: the beginning of the end?