DOUBLE TAX RELIEF

Matthew Rowbotham (Lewis Silkin) examines the Government’s consultation on double taxation for UK individuals in US LLCs and finds much to welcome, as well as some important issues still to resolve.

Andrew Stewart

Andrew Stewart (BDO) explores the new transfer pricing treatment of forex movements and highlights the additional compliance burden and technical uncertainty introduced by FA 2026.

Oliver Marre

The Upper Tribunal’s decision in McCabe shows how difficult it can be to challenge findings of fact when confronted with multi-factorial tests, writes Oliver Marre (5 Stone Buildings).

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) explains that the Upper Tribunal has largely eschewed the FTT’s extensive reliance on UK domestic law cases on ‘purpose’ when determining whether a treaty anti-abuse provision applies.

Kyle Rainsford

Kyle Rainsford (Norton Rose Fulbright) examines the first UK case about the interpretation of a purpose rule in a double tax treaty which extends the recent approach of Blackrock HoldCo 5 to the international fiscal arena.

Irfan Butt

Andrew Seidler

Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.

Sara Luder

Charles Osborne

Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.

Charlotte Anderson

Emily Szasz

Emily Szasz and Charlotte Anderson (Freshfields Bruckhaus Deringer) examine the FTT decision on the interaction between domestic appeals and MAPs which are provided for in double tax treaties.