According to the Financial Times (4 May 2014), the proposed takeover of UK-listed drug group AstraZeneca by Pfizer of the US has reignited the debate over tax competition between countries.
The OECD has said that bank secrecy for tax purposes is coming to an end, as countries and major financial centres commit to automatic exchange of information between jurisdictions.
Peter Stevens summarises the government’s proposals for charging tax on capital gains made by non-residents from disposals of UK residential property
Carolyn Steppler and Jane Scott consider whether it may be easier for some individuals to become non-UK resident under the SRT, now the concept of a ‘clean break’ has been removed
Peter Vaines comments on the operation of CGT on non-residents and ATED
Non-domiciled taxpayers are paying record amounts of tax on income that they generate in the UK, according to figures obtained by the law firm Pinsent Masons.
Withholding tax on dividends paid to non-EU funds held unlawful
Martin Zetter reviews relevant Danish and Dutch cases, plus interesting guidance issued by the US IRS
The monthly round-up by Chris Morgan, with news from the OECD’s BEPS project, two CJEU cases and the latest from France, India and Chile
Stephen Smith sets out the practical lessons from the Paul Daniel case concerning a taxpayer who realised a substantial capital gain whilst purporting to be working full-time abroad