On 25 September 2015, HMRC issued Revenue and Customs Brief 15 (2015) setting out its response to the UK Supreme Court's decision regarding hybrid
For many years, both the Canada Revenue Agency (CRA) and Her Majesty's Revenue and Customs (HMRC) have treated limited liability companies (LLC)
Rights-holders have welcomed proposals to significantly strengthen the powers of EU border control officials to detain and destroy goods which infringe the rights of IP holders in Europe.
We review below the Bribery Act 2010 (Act) which became law in April 2010 and will come into effect in April 2011, probably in stages - see here for further information.
The case concerned a "round the world" capital gains tax (CGT) avoidance scheme involving a trust, taking advantage of the (then) terms of the double taxation treaty between the UK and Mauritius (the treaty).
On 2 June 2010, HMRC announced that Extra-statutory concession B46 (ESC B46) will end on 31 March 2011.
HMRC has recently published new draft guidance setting out the circumstances when it would not normally enquire into whether what is seemingly an overseas company could be held to be controlled and managed in the UK and so be UK resident for tax purposes.
In November 2009 the Court of Appeal in Nokia Corporation v Her Majesty's Commissioners of Revenue & Customs referred questions to the ECJ following Nokia's challenge to UK Customs' policy of not detaining suspect counterfeit goods in transit through the UK from one non-EU country to another non-EU country without evidence of diversion on to the EU market.
The Institute of Chartered Secretaries and Administrators (ICSA) has published guidance on the proper purpose test that has been implemented under the Companies Act 2006 ("the Act").
Capital gains tax (CGT) is currently charged at a flat rate of 18 per cent.