Corporate

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  • Consultation on extending royalties withholding tax

    Article

    Submitted: 11 December 2017

    The Government has published a consultation document on the proposed extension of withholding tax to royalty payments connected with the exploitation of UK rights or property, which was announced in the November 2017 Budget.

  • Bringing non-resident companies within the CT regime

    Article

    Last Reviewed: 07 December 2017 / Submitted: 21 March 2017

    The Government has released proposals to bring the UK real property income of non-resident companies within the charge to corporation tax.

  • Bringing non-resident companies within the CT regime on UK property income and gains

    Article

    Submitted: 07 December 2017

    The Government has confirmed that it plans to bring non-resident companies within the scope of corporation tax on their UK property related income and gains with effect from April 2020.

  • HMRC extend transitional period for employer funded pension VAT costs

    Article

    Last Reviewed: 28 November 2017 / Submitted: 06 September 2016

    HMRC have announced an extension to 31 December 2017 of the transitional period allowing employers to take advantage of the 70:30 basis of recovering input VAT associated with occupational pension schemes.

  • Freedom of establishment and fiscal unity

    Article

    Submitted: 26 October 2017

    The Advocate General has suggested that Dutch rules restricting deductions for interest on a related party borrowing for investment in a foreign subsidiary were contrary to EU law.

  • EU Commission concludes Ireland granted State Aid to Apple

    Article

    Last Reviewed: 06 October 2017 / Submitted: 27 September 2016

    The EU Commission has decided that Ireland granted State Aid to Apple in the form of tax rulings confirming that Apple's Irish Companies could allocate profits to a non-resident head office.

  • Use of UK SPVs for insurance linked securities issuance

    Article

    Last Reviewed: 03 October 2017 / Submitted: 25 November 2016

    The Autumn Statement announced that the UK will introduce a new regime for UK insurance linked securities SPVs subject to the results of a further round of consultation on the tax and regulatory aspects.

  • HMRC consults on its engagement with large businesses

    Article

    Submitted: 29 September 2017

    HMRC is consulting on its process for assessing the tax risk posed by large businesses and how such businesses might be further encouraged to achieve Low Risk status.

  • FTT: first decision on the senior accounting officer regime

    Article

    Submitted: 28 September 2017

    A group finance director has succeeded in overturning penalty assessments under the senior accounting officer regime on the basis that, in all the circumstances, he had taken reasonable steps to ensure appropriate tax accounting arrangements despite material misreporting of VAT.

  • Renewal of FFI Agreements required

    Article

    Last Reviewed: 04 August 2017 / Submitted: 19 June 2017

    Foreign financial institutions (FFIs) with existing FFI agreements with the US Internal Revenue Service have been given an extended deadline until 24 October 2017 to renew those agreements.

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