WITHHOLDING TAXES

Emma Chamberlain OBE (Pump Court Tax Chambers) considers the new regime for non-doms from April 2025 and reviews the likely impact of the changes.

Paul Radcliffe

Reinhart Devisscher

After ten compromise texts and two years of political debate, agreement has finally been reached on new rules for EU withholding tax procedures. Paul Radcliffe and Reinhart Devisscher (EY) examine the detail and consider what’s next.

Deepesh Upadhyay

Dominic Robertson

Deepesh Upadhyay (Eversheds Sutherland) and Dominic Robertson (Slaughter and May) examine one of the most important withholding tax cases in years.

Brin Rajathurai

Rob Jones

Brin Rajathurai and Robert Jones (Freshfields Bruckhaus Deringer) review a useful exemption that is sometimes overlooked.

Irfan Butt

Andrew Seidler

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

Paul Radcliffe, David Wren, Reinhart Devisscher

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.

Dominic Robertson

Steve Edge

While the UK’s new digital services tax hogged the limelight in the recent Budget, much less attention was paid to the fact that the proposed extension of withholding tax on royalties paid to tax havens (announced at the previous Budget) was...

Paul Shaw

Paul Williams

Paul Shaw and Paul Williams (Bryan Cave Leighton Paisner) examine a recent tribunal decision on the nature of annual payments and platform agreements.

Dominic Foulkes

Jonathan Cooklin

Dominic Foulkes and Jonathan Cooklin (Davis Polk) consider some developments on the taxation of lending into UK acquisition finance structures.

Anne Fairpo

The changes in the current Finance Bill will bring rather more intellectual property royalties into the scope of withholding tax, as Anne Fairpo (Temple Tax Chambers) explains.

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