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Fasken | United Kingdom | 25 Sep 2015

HMRC’s post-Anson response to hybrid entity classification

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


Fasken | United Kingdom, OECD, Canada | 10 Sep 2015

Hybrid entity classification following the anson decision

For many years, both the Canada Revenue Agency (CRA) and Her Majesty's Revenue and Customs (HMRC) have treated limited liability companies (LLC)


Fasken | European Union | 7 Jul 2011

Proposal to extend the powers of customs to destroy counterfeit goods and parallel imports

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.


Fasken | United Kingdom | 16 Nov 2010

The Bribery Act 2010 and the pharmaceutical and medical device sectors

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.


Fasken | United Kingdom | 30 Jul 2010

HMRC v Smallwood and another 2010 EWCA Civ 778

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).


Fasken | Canada | 30 Jul 2010

End of concession for late filed returns

On 2 June 2010, HMRC announced that Extra-statutory concession B46 (ESC B46) will end on 31 March 2011.


Fasken | United Kingdom | 30 Jul 2010

HMRC release new guidance on company residence

HMRC has recently published new draft guidance setting out the circumstances when it would not normally enquire into whether what is seemingly an overseas company could be held to be controlled and managed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.


Fasken | United Kingdom, European Union | 25 Mar 2010

Customs detention

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.


Fasken | United Kingdom | 15 Jul 2009

Register of members: right to inspect subject to proper purpose test

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").


Fasken | United Kingdom | 2 Jun 2009

Incentivising executives - joint ownership plans and the tax benefits

Capital gains tax (CGT) is currently charged at a flat rate of 18 per cent.

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