Robert Langston considers the practical issues and opportunities arising from the new branch exemption introduced by FA 2011 Sch 13
Interest payable to overseas investors in UK debt securities is subject to UK withholding tax. Ben Jones and Deepesh Upadhyay examine the four commonly used mitigating routes
HMRC are seeking views on draft legislation, earmarked for Finance Bill 2012, to counter tax avoidance schemes exploiting double taxation agreements.
The objective of holding multinationals to account in relation to tax planning strategies – one of six stated ‘possible objectives’ – was discounted by a group of tax experts and practitioners reporting to the OECD in April on the case for greater disclosure of tax information.
The UK has become less attractive in recent years for firms that ‘rely more’ on capital allowances for plant and machinery and industrial buildings, according to research published by the Oxford University Centre for Business Taxation.
The Income Tax (Manufactured Overseas Dividends) (Amendment) Regulations, SI 2011/1787, amend SI 1993/2004 to take account of the reform of the taxation of foreign permanent establishments.
Bradley Phillips provides a one page overview of the CFC proposals set out in the 110 page consultation document
Helen Lethaby provides this month’s review of recent developments affecting the financial services industry