10 Tax Rankings
Chambers 2022
9 Tax Rankings
Legal 500 2022
Band 1 Tax
Chambers 2022, Europe-wide
9 giugno 2023 // Publication
On 27 April 2023, the Belgian legislator adopted a law (the “Mobility Law”) transposing Directive (EU) 2019/2121 (the “Mobility Directive”). The Mobility Directive provides for a new harmonised company law framework for cross-border conversions and divisions and adapts the already harmonised rules for cross-border mergers of limited liability companies within the EEA.
This newsletter draws your attention to some tax consequences of the Mobility Law.
8 giugno 2023 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition we report on the publication of the revised Finance Bill which includes amendments agreed in the House of Commons committee stage. We also cover an interesting case on whether interest payable under a funding arrangement which consisted of a series of short loans was subject to UK withholding tax. Finally, we report on HMRC’s publication of a new version of the DTTP1 form for DTTP renewal.
4 giugno 2023 // Publication
This article examines proposed regulations concerning the qualification of a real estate investment trust or a registered investment company as a domestically controlled qualified investment entity.
25 maggio 2023 // Publication
This month our new interactive guide includes: FCA Listing Rules and “small firms” consultations; tips legislation approved; proposed changes to holiday pay, working time, TUPE and non-competes; EU laws sunset clause removed; strike legislation changes; ESG pay targets; global share plans updates, HMRC consultations on employee trusts and stamp duty; Tax tribunal ruling on RSUs as retention pay, Acas guidance on mental health; new government guidance on ethnicity pay gap reporting and positive action; and the Pay Transparency Directive.
25 maggio 2023 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition we report on the passage of the Finance Bill through Parliament. We also cover some interesting cases on the taxation of a gain-linked payment from a company to its shareholder and the definitions of “tunnels” and “aqueducts” for capital allowances purposes. Finally, we report on the signing of the UK-San Marino Double Taxation Convention.
11 maggio 2023 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition we report on proposed amendments to the Finance Bill to be discussed in the House of Commons Committee Stage. We also report on updated HMRC guidance on uncertain tax treatment by large businesses, the unallowable purpose rule and late payment interest for failure to withhold tax. We cover regulations extending VAT disclosure rules to intra-group offshore supplies and a CJEU decision on the German taxation of resident and non-resident specialised property funds.
4 maggio 2023 // Publication
At the end of April, a Circular letter on the R&D salary withholding tax exemption was published which states that, as of 1 August 2023, the qualifying projects and programs must be registered before their start date to benefit from the exemption at all.
28 aprile 2023 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition we report on the consultations launched by HMRC and HM Treasury as part of this year’s Tax Administration and Maintenance Day, including in relation to stamp taxes reform. We also report on the passage of the Finance Bill through Parliament. There has been an interesting case on the taxation of subsistence expenses. We have also covered the new UK-Kyrgyz Republic double tax treaty and the publication of the International Tax Compliance (Amendment) Regulations 2023.
24 aprile 2023 // Publication
This month our one page guide looks at a range of topics including:
Increase to injury to feelings awards; the Government's whistleblowing review; pay transparency; our European guide to strike action; HMT's call for evidence on the Senior Managers and Certification Regime; the completed criminal market abuse review; and proxy and shareholder voting guidelines.
20 aprile 2023 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition we report on the passage of the Finance Bill through Parliament. There have been some interesting cases, including on whether the services of a TV presenter fell within the scope of IR35, the time limits applicable for HMRC to open an assessment in respect of unpaid offshore tax, and whether a taxpayer could appeal against HMRC’s exercise of discretion under Paragraph 30 Schedule 10 VATA 1994. We also cover the GAAR Advisory Panel’s opinion on an SDLT avoidance scheme.
30 marzo 2023 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition we report on the passage of the Finance Bill through Parliament. There have been some interesting cases on HMRC’s ability to open an enquiry into a voluntary SDLT return, the taxation of deferred remuneration reallocated to members of an LLP, whether the agency legislation applied in respect of workers supplied by an employment agency, whether the IR35 rules applied to services supplied through a partnership and the construction of Paragraph 12 Schedule 10 VATA 1994.
23 marzo 2023 // Publication
This month our two-page guide looks at a range of topics including: the Spring Budget, the four-day working week pilot report; the minimum service levels for rail services consultation; the FTSE Women Leaders Review; the Parker Review on ethnic diversity; the Court of Appeal’s decision on the duty to indemnify and protect employees from conviction; ET claim limit increases from April 2023; PRA consulting on CRD V pay rules for “small firms”; the Regulatory Initiatives Grid; and the ECJ ruling on UCITS / AIFMD rules and dividends.
23 marzo 2023 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition we report on the spring budget and Finance Bill 2023. There have been some interesting cases, including on the compatibility of UK group relief rules with EU law, on whether intangible assets were acquired by an LLP from related parties, on an ineffective SDLT sub-sale scheme and on the scope of HMRC’s power to disclose confidential documents. We have also reported on the publication of regulations designating activities as R&D activities under the Income Tax Act 2007.
16 marzo 2023 // Publication
The Spring Budget was delivered by the Chancellor of the Exchequer, Jeremy Hunt, on 15 March 2023 and contained measures aimed at achieving “long-term, sustainable economic growth”. The Spring Finance Bill 2023, containing legislation to implement many of the measures, will be published on 23 March 2023. In this tax alert, we summarise the key tax points relevant to large businesses.
If you would like to discuss any of the measures announced, please get in touch with your usual Linklaters contact
9 marzo 2023 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition we report on the date of the publication of the spring Finance Bill 2023. There have been interesting cases on when company cars constitute a taxable employee benefit, the VAT treatment of continuous supplies invoiced after the supplier leaves the VAT group, and the validity of Article 9a(1) of the VAT Implementing Regulation in the context of online platforms. Finally, we cover HMRC’s guidance on apportionment of consideration for mixed supplies for VAT purposes.
2 marzo 2023 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition we report on cases relating to an unsuccessful SDLT sub-sale scheme and an unsuccessful film financing scheme. We also report on the Supreme Court’s decision on whether the VAT zero rating for print newspapers extended to pre-2020 digital newspapers. We have covered HMRC’s publication of guidance on the SH03 form in the Stamp Taxes newsletter and HM Treasury’s publication of draft regulations amending the Anti-Money Laundering levy regulations.
24 febbraio 2023 // Publication
This month our two-page guide looks at a range of topics including: the Government’s draft Code of Practice on dismissal and reengagement; the Government’s response to WEC’s menopause and the workplace report; the EU Proposal for Directive on pay transparency and enforcement; the Private Member’s Bill on the right to request predictable terms and conditions; consultations and inquiry launched on minimum service levels during strike action; financial sector pay updates; HMRC’s Trust Registration Service guidance on non-registration penalties; and tax updates.
23 febbraio 2023 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition we report on royal assent of the SDLT (Temporary Relief) Act. There have been cases on the concept of “staleness” in the context of discovery assessments, the VAT predominant supply test and the compatibility of the UK group transfer rules with EU law. The EU has also updated its list of non-cooperative jurisdictions, and the response to the online sales tax consultation has been published.