06/01/2023
HMRC Fights Back:Two Restructuring Plans Refused Sanction by the English Court
For mid-market companies, HMRC is often a significant creditor, and following its experience in Houst, it was keen to resist being crammed down again.
Tax
05/31/2023
Review SAYE arrangements following HMRC bonus rates guidance, say experts
An SAYE plan offers eligible employees the opportunity to acquire shares in their employer, or parent, company on a tax-advantaged basis.
05/22/2023
Jersey and Guernsey response to Pillar Two Framework on global tax rates
The Islands will monitor implementation internationally and adapt their implementation of the tax rate accordingly to global developments.
05/22/2023
Irish Real Estate Loans - Recent Case Law
These may be Irish real estate loans or corporate loans of a multinational secured over the real estate of the group including Irish land or buildings.
05/22/2023
UK non-doms: what are the main political parties saying?
There is no arguing that this regime is of financial benefit to remittance basis taxpayers.
05/10/2023
Reserved Investor Fund proposals offer some tax advantages
The proposals are not only targeted at retail investors, they are also potentially relevant to institutions such as pension funds and insurance companies as well as other investor categories, such as certified high net worth investors.
04/25/2023
EU Global Minimum Tax Directive and Investment Fund Structures
An investment fund must meet several conditions to qualify for the safe harbour
04/24/2023
Moving to the UK and import taxes – Have you taken all your personal possessions (and art) with you?
It is therefore not surprising that one may be tempted to delay any non-essential parts of the move.
04/24/2023
Update on the developments of Hong Kong's proposed tax concession regime for family offices
The Amendments further recognize that up to 25% of the FIHV and the ESF Office may be owned by a charitable entity that is exempt from tax under section 88 of the IRO.
04/21/2023
Revisions to the proposed family office tax exemption regime in Hong Kong: the key takeaways
The legislation to implement the Scheme, the Inland Revenue (Amendment) (Tax Concessions for Family-owned Investment Holding Vehicles) Bill 2022 (the “Bill”) was gazetted on 9 December 2022.
04/19/2023
The Corporate Tax Planning Law Review - Ireland 2023
This chapter first appeared in the fifth edition of The Corporate Tax Planning Law Review published by Law Business Research.
04/18/2023
BVI economic substance: new clarification on tax residency status for BVI entities administered in Channel Islands and Isle of Man
As it relates to claims made under Rule 2, the recent amendments to the BVI Guidance Notes provide that where an entity's tax residency is Jersey, Guernsey or the Isle of Man, to claim tax residency there under Rule 2
04/18/2023
Dutch Supreme Court clarifies scope of lucrative interest tax regime, applicable to many forms of carried interest and sweet equity
The judgment is a welcome and long-awaited confirmation of the scope of the lucrative interest tax regime and relevant for all kinds of leveraged investments, such as carried interest, sweet equity and similar regimes.
04/11/2023
Experts provide insight into global tax fraud enforcement
Making the wrong move can have significant consequences, and in the UK, HMRC has demonstrated in recent years that no one is beyond reach.
04/06/2023
The proposed family office tax exemption regime in Hong Kong: a comparative view
In a previous briefing note, we discussed the licensing requirements for family offices under the Securities and Futures Ordinance in Hong Kong.
03/31/2023
No UK green tax policy review following Skidmore ‘very disappointing’
A permanent extension of the £1 million annual investment allowance (AIA) was also announced by the chancellor at the Spring Budget.
03/27/2023
Greenberg Traurig Launches State & Local Tax Podcast ‘GeTtin’ SALTy’
With most legislatures in session, Scarborough and Dobay have a lively conversation, touching on the key state and local tax legislative items state policy makers are currently considering as well as a few they are not.
03/27/2023
HMRC permitted to disclose taxpayer information to another taxpayer, court finds
The question before the Court of Appeal arose from an application from HMRC to the First-tier Tax Tribunal (FTT) for a direction permitting them to disclose to Bell information and documents.
03/24/2023
A snapshot of Hong Kong's proposed tax concession regime for family offices
The Bill is still under review by the Legislative Council of Hong Kong and this article refers to the provisions of the Bill as gazetted.
03/23/2023
New Condo-Hotel Tax Announced
Properties that are part of hotel rental pools previously enjoyed exemption from payment of real property tax