- Managers of Wealth - Legal - Wealth, private banking and asset management news and opinion

UK tax authority ‘particularly vigilant’ on transfer pricing, figures show

A total of 153 transfer pricing cases were settled during the year running to 31 March 2023.

Upper Tribunal rules on taxpayer liability for fixed penalty

Due to delays in issuing, HMRC had changed the date of compliance with the tribunal-approved information notice.

Simmons & Simmons: VAT Insights - June 2024

A round up of the Simmons & Simmons insights on VAT developments over the last month.

New Luxembourg tax bill aims to implement several income tax law changes

A provision in the draft bill sets out the obligations for the Luxembourg company reducing its share capital

Experts call for more consistency across tax regimes as UK considers reform

One area of variation suggested is HMRC’s powers for value added tax (VAT) and other indirect taxes.

Irish employers should review worker taxation classifications

This will be particularly relevant for businesses in certain sectors where Irish Revenue is likely to closely scrutinise the relationships with workers going forward.

Get up to speed with ESOP changes for 2024 in Ireland

This briefing summarises some of the main unapproved share option schemes available to companies in Ireland.

HMRC ‘dual role’ agents guidance of limited help to football clubs

Robotham was commenting after HMRC issued promotional material titled ‘Help with football agents' fees and dual representation contracts

Unallowable purpose and utilising existing losses

Arrangements entered into to enable a group to utilise trapped losses more quickly had an unallowable purpose.

IRS Issues New Ruling Policy on Spin-Off Transactions

New IRS Revenue Procedure Changes Ruling Practice for Retained Stock and Securities, Tax-Free Stock-for-Debt Exchanges and Debt Securities-for-Debt Exchanges

California property tax and Proposition 19

The $1 million non-principal residence exclusion would be eliminated entirely.

Important considerations when receiving an inheritance

Governing agreements often include restrictions on the rights of members to withdraw their interests

Foreign dividends reform ‘a boost Ireland’s holding company credentials’

The proposal is to apply the exemption to “foreign dividends and other types of distributions that represent income

VAT anti-abuse and domestic presumptions

Rebuttable presumptions based on the volume of turnover were an inappropriate and illegal basis for applying the abuse of law principle

Allen & Overy’s Scott Cockerham on tax insurance in green energy credit deals

NHS parking charges should be free of VAT, Court of Appeal rules

Having concluded on this point, the Court of Appeal considered whether non-taxation of NHS parking would create a distortion of competition.

Irish tax treatment of some intra-group payments to change from 1 April

The change is given legal effect by the Finance (No. 2) Act 2023 and was trailed in a feedback statement issued by the Irish Department of Finance in July last year.

Don't let your trust fall short: how tax season can reveal funding gaps

Another way to confirm your trust funding is to double-check the property tax bills for your real property

OECD approach to ‘Amount B’ a milestone but global tax challenges remain

Tax rules provide that transactions between connected parties should be taxed as if they were on arm's length terms.

Termination triggering discrimination claims: taxation

The question whether a payment is received in consequence of or otherwise in connection with termination of employment is to be construed widely