25 Jan 2024
Implications of IRS Cuts to Transactional No-Rule List – Marek Krawczyk
Partner and Head of US Business Tax, Marek Krawczyk and Ben Furtick of Certa Insurance Partners discuss the implications of the new IRS guidance for transactions and restructurings of multinational groups, in Bloomberg Tax.
22 Jan 2024
Andrew Parkes comments on the Capital Gains Tax benefits of being married
National Technical Director, Andrew Parkes, comments on the Capital Gains Tax benefits of being married, in The Daily Express.
12 Jan 2024
Miles Dean comments on the new global minimum corporation tax
Partner and Head of International Tax, Miles Dean, comments on the impacts of the new global minimum corporation tax, in City A.M.
11 Jan 2024
Can You Trust The Foundations? – Andrew Parkes
National Technical Director, Andrew Parkes, discusses protecting your family’s wealth in common law versus civil law jurisdictions via trusts and foundations, in IFC Review.
21 Dec 2023
Does HMRC have my cryptoassets in its sights?
Dion Seymour and Laura Knight discuss HMRC’s latest nudge letter campaign and the disclosure of cryptoassets, in AccountingWEB.
13 Dec 2023
The digital pound: A new form of Marmite for the financial sector?
Dion Seymour discusses the future of the digital pound and its recent attention from the Treasury Committee, in AccountingWEB.
5 Dec 2023
Dion Seymour comments on the UK government’s call for voluntary disclosure of crypto
Dion Seymour comments on the UK government’s call for crypto users to voluntarily disclose any unpaid capital gains or income taxes, in CoinDesk.
20 Nov 2023
Miles Dean comments on the implications of removing the non-domiciled tax status
Head of International Tax, Miles Dean, comments on the implications of the Labour Party’s pledge to scrap the non-domiciled tax status, in the Financial Times.
8 Nov 2023
Double Tax Treaties: An ex-Insider’s View of HMRC’s Treaty Position – Andrew Parkes
During my time at HMRC, I worked with the Tax Treaty team on the two Bank Levy Double Taxation Relief treaties and delivered training to HMRC staff on the UK’s treaties generally. Interestingly, HMRC does have its own model treaty, but this is not published. It is, however, closely modelled on the OECD model convention. […]
8 Nov 2023
The Taxman Cometh – Soon – Andrew Parkes
We have mentioned previously (see our January 2022 Newsletter) that the UK will seek to tax any income from a trade carried on in the UK by a non-resident, but that this is blunted where there is a Double Taxation Agreement (DTA) between the UK and the country of residence of the trader. Where there […]
8 Nov 2023
The Paradox of Tax Planning and Morality: A review of Taxpayer v HMRC – Chimezirim Echendu
Introduction In Finance Act 2013, the UK introduced a statutory residence test (SRT) to provide an objective way of determining the residence of individuals. The test, although based substantially on day counting and days spent in the UK, also relies on the substance and quality of an individual’s residence to determine tax residence. As days […]
8 Nov 2023
But why? – Not the cry of every toddler, but why a relief is due – Andrew Parkes
One of the real joys (and I’m not being sarcastic here) of working in International Tax is that what seems to be the simplest of questions can have the most hidden of answers. The UK’s distribution exemption (i.e. dividends received from underlying subsidiaries are exempt from UK taxation) for small companies is only available where […]