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Results: 1-10 of 354

Corporate Treasury - key considerations and a review of market developments
  • Clifford Chance
  • United Kingdom, OECD, European Union
  • October 20 2016

This year has been a volatile one for corporate treasurers and their advisors and Brexit added yet another element of uncertainty. Here, Clifford


Deutsche Bank and UBS tax avoidance schemes succeed
  • RPC
  • United Kingdom
  • May 1 2014

The cases of DB Group Services (UK) Limited v HMRC and HMRC v UBS AG were heard together by the Court of Appeal in November 2013 and the decision


High Court of Australia upholds imputation benefits of hybrid instrument (Mills v Commissioner of Taxation)
  • Russell McVeagh
  • New Zealand, Australia
  • November 19 2012

The High Court of Australia has unanimously held that the provision of franking credits as part of the return on a hybrid instrument was an "incidental purpose" to that of the overall purpose of raising capital for the issuing banking group


UBS AG and DB Group Services v HMRC: tax avoidance scheme succeeds at the Upper Tribunal
  • RPC
  • United Kingdom
  • November 2 2012

The eagerly awaited decision of the Upper Tribunal (UT) in the case of UBS AG and DB Group Services (UK) Limited v HMRC2 has now been released


Tax avoidance scheme succeeds at the Upper Tribunal
  • RPC
  • United Kingdom
  • October 5 2012

The eagerly awaited decision of the Upper Tribunal (‘UT’) in the case of UBS AG and DB Group Services (UK) Limited v HMRC 2012 UKUT 320 (TCC) has now been released


Countdown to March 18, 2012: are you ready?
  • Morrison & Foerster LLP
  • USA
  • October 21 2011

Despite this summer’s extension of the FATCA withholding rules (scheduled to be phased-in over 2014 and 2015), FATCA’s next effective date (March 18, 2012) will continue to greatly impact global financial transactions


IRS issues new timeline for implementation of FATCA
  • Lowenstein Sandler LLP
  • USA
  • August 18 2011

The IRS has issued a new timeline for implementing the onerous requirements imposed on foreign financial institutions (including foreign hedge funds and private equity funds) by the Foreign Account Tax Compliance Act (“FATCA”


Employee bonus schemes involving forfeitable shares - Part 2
  • CMS
  • United Kingdom
  • February 17 2011

HM Revenue & Customs ("HMRC") has won yet another case on the tax treatment of an annual bonus scheme involving shares, which was used before 2004 since when legislation has been significantly tightened so as effectively to block further use of these schemes


The Government makes key announcements on anti-avoidance measures
  • Herbert Smith Freehills LLP
  • United Kingdom
  • December 7 2010

Yesterday, the Government launched a 'study programme' to establish whether an effective General Anti-Avoidance Rule (GAAR) could be developed to form part of the UK tax system


ISDA protocol addresses new withholding rules for dividend equivalent payments
  • Eversheds Sutherland (US) LLP
  • USA
  • September 1 2010

On August 23, 2010, the International Swaps and Derivatives Association (ISDA) announced a new Protocol intended to address new U.S. withholding tax rules for certain notional principal contract payments. Under