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VAT, employee incentives and vouchers

The desire to incentivise employees did not constitute a sufficient business purpose within the meaning of Article 26(1)(b).

MTD income tax pilot attracts just over 1,000 volunteers

The data, acquired from HMRC via a freedom of information request, shows that the number of annual sign ups has fallen from 877 in 2018-19 to only 26 in the most recent full year, 2020-21.

Increased US Gift and Estate Tax Exemptions and Further Planning Opportunities in 2022

The maximum gift and estate tax rate remains at 40% of the fair market value of the relevant assets.

US Tax Issues For Non-US Crypto Investors

This is because, for US tax purposes, gain on the sale of property is generally treated as tax-free foreign source gain in the hands of a foreign seller.

How Can Financial Institutions Achieve Efficient Regulatory Reporting?

When the accountholders provide their information to a financial institution, they expect that the institution will use their information to comply with the law.

Ed Renn featured in Accounting Today's "IRS Having Difficulty Processing Power of Attorney Forms"

Last year as part of Biden’s proposals we suddenly had refundable Child Tax Credits and the change to the Employee Retention Tax Credit on the employer’s side.

Jersey to introduce taxation for enveloped property transactions

Guernsey introduced such a measure back in November 2017 in a law which reflects much of the same language as that now proposed in Jersey.

OECD releases latest edition of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein and taxpayers need clear guidance

New Attribution Requirement Denies Foreign Tax Credits for Certain Withholding Taxes (And Other Taxes)

In particular, the Final Regulations adopt a new “attribution requirement” (Attribution Requirement) that restricts the availability of FTCs to foreign taxes that the Treasury and the IRS consider to be similar to US taxes.

The Mauritius FSC clarifies requirements to meet substance conditions

As a reminder, effective 1 January 2019, the deemed tax credit regime whereby companies holding a Category 1 Business Licence were entitled to claim a deemed tax credit of 80% was abolished and replaced by a partial exemption regime on qualifying income.

Italian tax authorities provide new guidance on the tax treatment of Liechtenstein family foundations

The asset was intended to be sold and the proceeds so derived by the Stiftung were to be distributed to the heirs of the founders.

The global minimum tax rate: Are we nearly there yet?

On 20 December 2021, the OECD published keenly awaited model rules designed to implement Pillar Two of its ambitious plans to reform international taxation.

Employee Benefits, Trusts and Tax: Employers Beware

While the underlying law is relatively clear and well-established, there are still a few lesser-known legal risks to which employers are exposed

UK consults on proposed global minimum tax for multinationals

The government’s consultation seeks views on the proposed tax - which will be operated on a country-by-country basis - and its application in the UK, including who the rules apply to, transitional rules and how firms within scope should report and p

What You Need to Know About the Taxation of NFTS

Given the lack of guidance from the IRS on such gifts, donors and recipient charities face a number of tax uncertainties.

UK launches consultation on domestic implementation of global minimum tax for large multinational groups

The UK government has today (11 January 2022) published a consultation seeking views for how a worldwide 15% minimum corporation tax should be domestically implemented.

EU publishes minimum corporate tax rate directive

Countries signing up to the OECD deal are not obliged to introduce the pillar two rules, but if they do so, they must follow the approach taken in the OECD model rules.

Lawpath unveils on-demand accounting services

There is an increasing overlap between legal and accounting, and so this partnership with Lawpath will ensure businesses right around Australia receive expert on demand advice to stay ahead and succeed with their business operations.

Global minimum tax rate: OECD publishes detailed rules

Countries are not obliged to introduce pillar two into their own domestic laws.

Private Client 2022 UK & Global Overview

The editors discuss a time of overwhelming change and some of the investment trends in the private client arena.