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Restructured loans did not circumvent withholding tax obligations

The original lender then used the proceeds of the assignment to the Guernsey entity to provide a new loan to Hargreaves.

ATAD 2 documentation requirement – tailored approach

The complexity of ATAD 2 and its related documentation requirement should not be underestimated

Fair Procedures in Irish Tax Appeals

The decision serves as another example of the Irish Courts' reluctance to interfere in the TAC's running of live tax appeals, and as a reminder to taxpayers to prepare and argue their full case before the TAC.

Brazil: Provisional Measure 1.171/2023 – new tax rules on foreign investments

It also clarifies the tax treatment of trusts with respect to both income and capital gains produced by trust assets and the tax treatment of distributions made to beneficiaries.

The perils of disorganisation – who's the winner?

Mr Dines was a 'shrewd' (in the judge's words) businessman but 'hopelessly disorganised' with his paperwork – leading to a bitter fight between his children and second wife in Court over properties worth more than £1m.

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.

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.

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.

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.

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.

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.

EU Global Minimum Tax Directive and Investment Fund Structures

An investment fund must meet several conditions to qualify for the safe harbour

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.

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.

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.

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.

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

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.

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.

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.