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United Kingdom

Archive: United Kingdom

This content is from: European Union

Advocate General opinion in FII GLO encourages claimants

The Franked Investment Income Group Litigation (FII GLO) concerning claimants' rights to recover overcharged tax from HM Revenue & Customs (HMRC) has been batted back and forth between the UK courts and the European C...
September 30 2013
This content is from: United States

Unlocking MAP disputes: Is mediation the key?

Item 14 of the OECD's Action Plan on base erosion and profit shifting (BEPS) aims to devise solutions to obstacles preventing countries from resolving cross-border disputes under the mutual agreement procedure (MAP). ...
By Joe Dalton
September 30 2013
This content is from: European Union

Multilateral cooperative compliance: The next step?

Machiel Lambooij, of Freshfields Bruckhaus Deringer, and chair of IFA's subcommittee on enhanced relationships, discusses the potential application of cooperative compliance arrangements in cross-border situations, in...
September 30 2013
This content is from: United States

International tax transparency: Past, present and future

Harm Oortwijn, director of international tax and reporting at Paramount Pictures, and owner/director of EA Tax Services BV, looks at the background and present trends regarding international tax transparency, explorin...
September 30 2013
This content is from: United Kingdom

Labour plans to increase taxes for UK’s big businesses

Although Ed Miliband’s pledge to help smaller businesses has been welcomed by some, the strategy behind the planned changes has not been without criticism. In order to deliver a tax break to smaller businesses, Labour...
September 30 2013
This content is from: United Kingdom

CIOT passes Riches on to Smith & Williamson

Tina Riches will become head of the national tax function at Smith & Williamson, from January 2014, replacing the retiring Richard Mannion. Riches joins Smith & Williamson from the Chartered Institute of Taxation (CIO...
September 29 2013
This content is from: United States

BB&T loses STARS case but ruling clouds legitimate tax planning rights in US

US bank BB&T is considering appealing Friday’s Court of Federal Claims defeat, despite the case judge describing its tax credit generator scheme with Barclays as an economically meaningless tax shelter. While some adv...
By Joe Dalton
September 25 2013
This content is from: United Kingdom

Compensating adjustment mechanism: Another loophole closed

The UK government is changing the compensating adjustment mechanism in its transfer pricing legislation, which will affect services companies and loans from individuals or partnerships to companies that are more than ...
By Sophie Ashley
September 25 2013
This content is from: United States

Has US Tax Court’s concession to BNY Mellon opened new chapter in STARS cases?

The Bank of New York Mellon’s (BNY Mellon) US Tax Court victory on Monday could see a new wave of taxpayer claims in structured trust advantaged repackaged securities (STARS) cases.
By Joe Dalton
September 25 2013
This content is from: United Kingdom

HMRC upping ADR capacity for large taxpayers after successful pilot

HM Revenue & Customs (HMRC) has published an evaluation of its pilot on alternative dispute resolution (ADR) for large and complex tax cases, and says it will up its mediation capacity after ADR proved to be a useful ...
By Joe Dalton
September 25 2013
This content is from: United Kingdom

Ed Miliband: UK Labour Party would raise corporation tax

Ed Miliband, leader of the UK opposition Labour Party, has said he would reduce the tax burden on small businesses at the expense of big corporations by raising the corporate tax rate if elected.
By Matthew Gilleard
September 23 2013
This content is from: United States

BEPS: A new approach for taxing multinationals is needed

The OECD’s work on base erosion and profit shifting (BEPS) is in the spotlight of worldwide taxation. Based on the Action Plan from last July and on two other reports – one published in March 2012 entitled Hybrid Mism...
September 23 2013
This content is from: United States

Shearman & Sterling and Tremonti Vitali Romagnoli Piccardi e Associati announce coopera...

Global law firm Shearman & Sterling has entered into a “best-friends” cooperative agreement with Italian specialist tax firm Tremonti Vitali Romagnoli Piccardi e Associati which sees the firms formalise their collabor...
By Matthew Gilleard
September 18 2013
This content is from: Guernsey

Guernsey signs tax deal with Switzerland as jurisdictions work to change perception

Guernsey has signed a tax information exchange agreement (TIEA) with Switzerland, taking the number of such agreements signed by the UK crown dependency to 46.
By Matthew Gilleard
September 17 2013
This content is from: Austria

Why the European Council’s legal service opinion does not mean the end of the road for ...

After last week’s opinion from the European Council's legal service stated that part of the residence principle of the proposed European financial transaction tax (FTT) is incompatible with European law, some proponen...
By Matthew Gilleard
September 17 2013
This content is from: European Union

UK R&D expenditure hits record high

Business spending on research and development (R&D) in the UK rose by 8% in 2012, as companies moved to take advantages of tax incentives on offer. R&D expenditure hit £11.9 billion, a record high which is £2 billion ...
By Matthew Gilleard
September 17 2013
This content is from: United States

IRS Releases “Corrections” to FATCA Regulations

The IRS has published "technical corrections" to the final FATCA regulations, reports Burt Staples & Maner
By ITR Correspondent
September 15 2013
This content is from: United Kingdom

Specialist tax counsel Jolyon Maugham joins Devereux Chambers

Devereux Chambers has added Jolyon Maugham from 11 New Square to its pool of specialist tax counsel.
September 15 2013
This content is from: United States

Tax justice campaigners: Companies’ “duty” to minimise tax exposed as false

Tax justice campaigners have commissioned a formal legal opinion from law firm Farrer & Co, which states that UK company directors have no fiduciary duty to their shareholders to mitigate their tax liability through t...
By Matthew Gilleard
September 10 2013
This content is from: United States

Cameron Cosby joins Hogan Lovells as a tax partner
By ITR Correspondent
September 09 2013
This content is from: United States

G20 communiqué drives BEPS action forward but implementation will be a “nightmare”

G20 leaders met in St. Petersburg last week, with international taxation once again high on the agenda.
By Matthew Gilleard
September 09 2013
This content is from: European Union

Legal opinion means EU FTT to be further watered down but not derailed

The EU member states introducing the financial transaction tax (FTT) may be forced to water down the European Commission’s proposal if they want to make it stick, after the EU Council’s legal service said part of the ...
By Joe Dalton
September 09 2013
This content is from: Ireland

Maples & Calder takes partner from Mason Hayes & Curran
By ITR Correspondent
September 08 2013
This content is from: United Kingdom

Seven reasons to choose a boutique tax recruitment agency

When choosing a specialist recruitment agency, the size of the company can have a significant impact on how far that agency can be trusted to deliver the work, says Izabela Hollander-Bolton of IBH Executive
September 08 2013
This content is from: United States

Navigating BEPS with transparency and technology

Internationally coordinated efforts to update taxation rules have never been stronger. With these changes come new challenges for taxpayers. Brian Tully, vice president and head of ONESOURCE Transfer Pricing for the T...
September 04 2013
This content is from: United Kingdom

HMRC launches ADR for SMEs and says evaluation of large business pilot imminent

After a two year trial, HM Revenue & Customs (HMRC) is launching its alternative dispute resolution (ADR) service for small businesses and individuals, and the introduction of the large taxpayer service may not be far...
September 04 2013
This content is from: European Union

ECJ Advocate General favours Aegis over HMRC on claim limitation question

EU taxpayers will welcome this morningâ€™s Advocate General opinion in the FII GLO litigation which said the UK is not allowed to curtail a claim limitation period retrospectively and without notice.
By Joe Dalton
September 04 2013
This content is from: United Kingdom

Fichardt leaves BLP for Clifford Chance

Clifford Chance announced today that Liesl Fichardt, leader of Berwin Leighton Paisner’s contentious tax practice, is joining its London office.
September 03 2013
This content is from: European Union

European Court hears Felixstowe Dock case on UK relief claims for non-EU groups

Hutchison Whampoa group companies were battling HM Revenue and Customs (HMRC) in the European Court of Justice (ECJ) yesterday in a case testing whether consortium loss relief may be claimed in the UK by a surrenderin...
By Joe Dalton
September 03 2013
This content is from: United Kingdom

MAP becoming more popular in the UK

On September 2 2013, the OECD released its 2012 mutual agreement procedure (MAP) statistics of its member countries and of partner economies that agreed to provide such statistics.
By ITR Correspondent
September 03 2013
This content is from: United States

Syria situation likely to stall G20 tax progress

While G20 rhetoric repeatedly trumpets tackling tax evasion as a key action item, events in Syria are likely to dominate proceedings in Russia. Tax will not be sidelined for long, though.
By Matthew Gilleard
September 03 2013