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Results: 1-10 of 21

The UK moves a step closer to enacting a general anti-avoidance rule

  • Baker & McKenzie
  • -
  • United Kingdom
  • -
  • March 20 2012

An advisory committee commissioned by the UK government has published a report in which it recommends the enactment of a narrowly focused general anti-avoidance rule

UK to introduce tax exempt transparent fund vehicle

  • Baker & McKenzie
  • -
  • United Kingdom
  • -
  • April 27 2011

The UK Government announced in the recent 2011 Budget that it will legislate in 2012 to introduce a new authorised fund regime for a tax transparent vehicle which is suitable for the new UCITS IV master fund structure, cross-border pooling of pension funds and life insurance funds

UK tax treatment of Delaware LLC: the Swift case

  • Baker & McKenzie
  • -
  • United Kingdom
  • -
  • March 19 2010

A recent decision of the UK's First-tier Tribunal (Swift v HMRC 2010 UKFTT 88 (TC)) dealt with the legal status of Delaware Limited Liability Companies ("LLCs") for UK tax purposes and appears to undermine the generally accepted view (and HM Revenue & Customs' ("HMRC") current practice) regarding the UK tax status of Delaware LLCs

UK government reveals radical proposals for foreign branch taxation and interim reforms to CFC rules for spring 2011

  • Baker & McKenzie
  • -
  • United Kingdom
  • -
  • July 28 2010

On 27 July 2010, HM Treasury published details of the aims and scope of the interim improvements to the UK's controlled foreign companies ("CFC") rules and the options for the introduction of a foreign branch profits exemption that were anticipated in the UK Government's Emergency Budget on 22 June

Corporate tax changes: what can we expect from the coalition government?

  • Baker & McKenzie
  • -
  • United Kingdom
  • -
  • May 25 2010

The new Chancellor, George Osborne, will present an Emergency Budget on 22 June

UK emergency budget: limited corporate tax reforms for now, more to come in the future

  • Baker & McKenzie
  • -
  • United Kingdom
  • -
  • June 23 2010

The UK Coalition Government delivered its first set-piece on 22 June, in the form of an emergency budget

Exemption for foreign branches: new opt-in regime from 2011

  • Baker & McKenzie
  • -
  • United Kingdom
  • -
  • December 1 2010

As part of the package of measures announced on 29 November 2010, the Government has published detailed proposals for reforming the taxation of foreign branches of UK companies

UK tax treatment of dividends paid following capital reductions: UK Government clarification

  • Baker & McKenzie
  • -
  • United Kingdom
  • -
  • March 3 2010

Earlier this month, we published an alert which described a new approach by HM Revenue & Customs ("HMRC") to the UK tax treatment of dividends paid out of reserves by a UK company following a reduction of capital

HM Treasury & HMRC publish long-awaited discussion document on proposals for CFC reform

  • Baker & McKenzie
  • -
  • United Kingdom
  • -
  • March 3 2010

HM Treasury and HM Revenue & Customs ("HMRC") have published their eagerly anticipated discussion document on proposals for reform of the UK's controlled foreign companies ("CFC") rules

New United Kingdom-Hong Kong Double Taxation Agreement brings planning possibilities

  • Baker & McKenzie
  • -
  • Hong Kong, United Kingdom
  • -
  • July 15 2010

Until now, there has been no comprehensive Double Taxation Agreement ("DTA") between the United Kingdom and Hong Kong, so businesses and individuals will welcome the fact that a first full DTA was signed on 21 June 2010

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