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430 results found

Article

RPC | United Kingdom | 30 May 2019

First-tier Tribunal - option granted to director not “employment related” under deeming provision

On 8 April 2019, the First-tier Tribunal held that an option granted to a company director was not an employment-related securities option (ERSO)

Article

Brodies LLP | United Kingdom | 15 Oct 2018

Don’t be taken by surprise by insolvency proceedings - lessons from Patisserie Valerie

It’s been reported that the board of directors of AIM-listed Patisserie Holdings plc, which owns the Patisserie Valerie chain of cafés, was not aware

Article

Squire Patton Boggs | United Kingdom | 3 Aug 2017

Development Securities - A New Line in the Sand

The UK rules for determining the tax residence of a company are relatively straightforward, and yet their application by HM Revenue and Customs

Article

DAC Beachcroft | United Kingdom | 4 Oct 2016

Tackling boardroom excess: the new criminal offence for corporates failing to prevent tax evasion

Theresa May is expected to push ahead with David Cameron's plans to hold companies criminally liable where they fail to stop their employees

Article

Guernsey Finance | United Kingdom, OECD, European Union, etc. | 18 Aug 2016

Investments funds and why substance is key - white paper

In the current climate of regulatory reforms, and the political impetus behind improving tax transparency, the need to prove that an offshore fund

Article

RPC | United Kingdom | 4 Jul 2012

Brown and others v InnovatorOne plc

A recent judgment of the High Court in Andrew Brown and ors v InnovatorOne plc and Ors 2012 EWHC 1321 (Comm) is welcome news for professional advisers who may have acted for clients involved in the design, implementation or distribution of tax efficient arrangements.

Article

RPC | United Kingdom | 6 Jun 2012

Brown v InnovatorOne plc good news for advisers involved in tax mitigation structures

A recent judgment of the High Court in Andrew Brown and ors v InnovatorOne plc and Ors 2012 EWHC 1321 (Comm) is welcome news for professional advisers who may have acted for clients involved in the design, implementation or distribution of tax efficient arrangements.

Article

ENSafrica | South Africa | 12 Oct 2011

Case law guidance on effective management

The concept of the "place of effective management" was considered in the recent judgment of the Western Cape High Court in the matter between The Oceanic Trust Co. Ltd N.O, and the Commissioner for the South African Revenue Service ("SARS") (as yet unreported).

Article

RPC | United Kingdom | 7 Oct 2011

Personal liability for directors no escape from the taxman

One of the criticisms that is often made of the UK’s complex insolvency legislation is that it is too easy for the directors of a company to put it into liquidation or administration, ‘dump’ the company’s debts and then effectively start the same business again under the guise of a new company.

Article

Gowling WLG | United Kingdom | 23 Sep 2011

Offshore companies: are they being managed appropriately?

Best practice recommendations, as noted in our alert dated 24 November 2009, include the following.

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