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26 results found

Article

Cadwalader Wickersham & Taft LLP | United Kingdom | 26 Apr 2019

UK Real Estate Update

With effect from 6 April 2019, non-UK residents will become subject to tax on chargeable gains arising from the disposal of all UK land, including

Article

Cadwalader Wickersham & Taft LLP | United Kingdom, OECD, European Union | 31 Oct 2018

UK Budget 2018 - Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2018 on 29 October 2018. The Budget was delivered against the backdrop

Article

Cadwalader Wickersham & Taft LLP | United Kingdom | 21 Feb 2018

High Court Decision Confirms the Availability of the Protection of Litigation Privilege in the Context of Internal Investigations

On 8 May 2017, the Chancellor of the High Court in Bilta v RBS confirmed that in certain circumstances litigation privilege may protect documents

Article

Cadwalader Wickersham & Taft LLP | United Kingdom | 6 Dec 2012

Uk Chancellor’s Autumn statement 2012: key taxation aspects

The Autumn Statement of the UK Chancellor of the Exchequer, presented to Parliament on 5 December 2012, was delivered with attention to three main themes: protecting the UK economy, growth and fairness.

Article

Cadwalader Wickersham & Taft LLP | United Kingdom | 27 Aug 2010

Group mismatch schemes: proposed legislation and open meeting on 23 July 2010

In the Budget held on 24 March 2010, HMRC published a discussion document regarding the proposed introduction of a generic or principles-based rule to respond to certain arrangements termed "group mismatch schemes".

Article

Cadwalader Wickersham & Taft LLP | United Kingdom | 27 Aug 2010

Loan relationships and derivative contracts: derecognition of income

The summer has seen a number of examples of HMRC acting to limit tax avoidance involving accounting (and, therefore, tax) derecognition of credits arising on a company's loan relationships and derivative contracts.

Article

Cadwalader Wickersham & Taft LLP | United Kingdom | 27 Aug 2010

Debt buy-back guidance published

HMRC has now published guidance in its Corporate Finance Manual on the changes to the connected party loan relationships rules which relate to debt buy-backs.

Article

Cadwalader Wickersham & Taft LLP | United Kingdom | 27 Aug 2010

Reform of the controlled foreign companies (“CFC”) legislation

HM Treasury has now produced more details regarding what will and what will not be dealt with as a part of the interim reform to the CFC legislation proposed to be included in Finance Bill 2011 next year.

Article

Cadwalader Wickersham & Taft LLP | United Kingdom | 27 Aug 2010

Consultation on exemption for profits of foreign branches

On 27 July 2010, the Government launched a consultation on reforming the taxation of profits arising from overseas branches of UK tax-resident companies with a view to introducing an exemption in relation to those profits (and a corresponding restriction of loss relief).

Article

Cadwalader Wickersham & Taft LLP | United Kingdom | 27 Aug 2010

The Double Taxation Treaty passport

As from 1 June 2010, corporate lenders in jurisdictions with which the UK has a Double Taxation Treaty containing an interest or income from debt claims Article may apply for a Double Taxation Treaty Passport ("Treaty Passport").

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