In its policy paper entitled "Partnerships Review: Proposed NICs changes for (i) Disguised Employment and (ii) Profit Deferral under Alternative
HMRC published this week a consultation paper entitled "Review of tax rules on partnerships: disguised employment and profit and loss allocation
On 2 October 2012, HM Revenue & Customs (HMRC) published a summary of industry responses to their earlier consultation paper of 27 March 2012.
There have been several cases in Europe and beyond over the past few years concerning the concept of beneficial ownership under double tax agreements (“DTAs”).
HM Revenue & Customs published on 27th March 2012 a consultation paper with proposals to amend certain income tax rules affecting interest payments.
The judgment of Mr Justice Mann in the Upper Tier Tribunal in Anson v Revenue and Customs Commissioners (FTC392010) was published on 5 August 2011.
The full details of the UK's new Double Tax Treaty Passport Scheme ("Scheme") have now been announced by HM Revenue & Customs ("HMRC").
A recent decision of the UK's First-Tier Tribunal creates uncertainty in relation to the commonly accepted UK tax treatment of interests in Delaware Limited Liability Companies (Mr Swift v Commissioners, TC00399).
Following our previous Fried Frank memoranda on the topic of the UK's bank payroll tax (11th December and 21st December 2009), the UK tax authority, HM Revenue & Customs ("HMRC"), has on 12th March 2010 issued a series of further clarifications and limitations on the scope of the tax.
A further discussion document relating to the proposed reforms of the UK’s controlled foreign companies regime has now been published, as envisaged by the HM Treasury and HM Revenue & Customs representatives at the joint meeting with stakeholders held on 9th November last year (see "Update on the Reform of the UK’s CFC Tax Regime", 10th November).