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Results: 1-10 of 46

"Extreme shopping": HMRC legislation to counter treaty shopping: thoroughly draconian

  • Herbert Smith Freehills LLP
  • -
  • United Kingdom
  • -
  • August 5 2011

On 1 August, just before the summer break, HM Revenue & Customs (HMRC) published a "Technical Note" and draft legislation (together, the "Note") entitled "Tax Treaties Anti-avoidance"

High Court holds that HMRC disclosure of taxpayer information not unlawful

  • Herbert Smith Freehills LLP
  • -
  • United Kingdom
  • -
  • November 26 2013

The High Court has ruled that Her Majesty's Revenue and Customs ("HMRC") did not act in breach of confidentiality provisions in disclosing

ECJ rules that the stamp duty reserve tax charge on entry into a clearance system is illegal under EU law; may have wider implications

  • Herbert Smith Freehills LLP
  • -
  • European Union, United Kingdom
  • -
  • October 5 2009

In a case last week, HSBC Holdings plc and Vidacos Nominees Ltd v HMRC (C-56907), the European Court of Justice (“ECJ”) held that the 1.5 UK stamp duty reserve tax ("SDRT") charge on the issue of shares into EU clearance systems is illegal

Gaines-Cooper decision UK tax residence for individuals

  • Herbert Smith Freehills LLP
  • -
  • United Kingdom
  • -
  • April 29 2010

The recent decision of the Court of Appeal in Gaines-Cooper (R (on the application of (1) Robert John Davies (2) Michael John James) v Revenue & Customs Commissioner: R (on the application of Robert Gaines- Cooper) v Revenue & Customs Commissioners 2010 EWCA Civ 83) has attracted a great deal of publicity

UK Supreme Court refuses to extend privilege to accountants

  • Herbert Smith Freehills LLP
  • -
  • United Kingdom
  • -
  • January 23 2013

The Supreme Court confirmed today that legal advice privilege ("LAP") cannot be claimed in respect of confidential communications between accountants

HMRC v Philips Electronics UK Limited

  • Herbert Smith Freehills LLP
  • -
  • European Union, United Kingdom
  • -
  • April 26 2012

Advocate General’s opinion: UK loss relief rules for branches breach EU law

UK SDRT charge on an issue of ADRs in respect of shares in a UK company breaches EU law

  • Herbert Smith Freehills LLP
  • -
  • United Kingdom
  • -
  • April 3 2012

The recent First tier Tribunal decision in HSBC Holdings and Bank of New York Mellon Corporation v The Commissioners for HMRC contains good news for companies located in Europe seeking to raise capital

Budget 2011 - putting “fuel in the tank of the economy”

  • Herbert Smith Freehills LLP
  • -
  • United Kingdom
  • -
  • March 23 2011

The Chancellor of the Exchequer today handed down the 2011 Budget

Controlled foreign companies (CFC)

  • Herbert Smith Freehills LLP
  • -
  • United Kingdom
  • -
  • September 27 2011

The CFC rules are a complex set of anti-avoidance rules that broadly seek to attribute the income and profits (but not gains) of certain subsidiaries located in tax havens or low tax jurisdictions where that income has been artificially diverted from the UK to the UK parent or holding company

Taxation of non-domiciled individuals

  • Herbert Smith Freehills LLP
  • -
  • United Kingdom
  • -
  • September 27 2011

Under current rules, non-UK domiciled individuals are liable to UK tax only on the income and gains which arise in the UK