10 Tax Rankings
Chambers 2022
9 Tax Rankings
Legal 500 2022
Band 1 Tax
Chambers 2022, Europe-wide
23 marzec 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 marzec 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 marzec 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 marzec 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 marzec 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 luty 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 luty 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.
8 luty 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 an employment tax case relating to whether a “gift” was earnings from employment, and a case in which the scope of privilege was considered. Internationally, the OECD has released some technical guidance on the GloBE (including dealing with debt releases and RT1) and HMRC has issued guidance on disclosure under the Mandatory Disclosure Rules.
8 luty 2023 // Publication
As per the law of 20 November 2022 (B.S., 30 November 2022, the deadline to file a tax protest (“reclamation”/”bezwaar”) for income tax purposes has been extended from six months to one year. Said deadline is in compensation for the extension of the statutes of limitations in favour of the Tax Administration that has been introduced by the Law (e.g. new statutes of limitations for tax audits from three years up to ten years). The deadline starts to run as from the third working day following the date on which the tax assessment was sent out to the taxpayer.
26 styczeń 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 an interesting case on whether input VAT incurred by an acquiring company on a reverse takeover and fund raising was recoverable. We also cover a decision on whether disqualifying arrangements were in place preventing EIS relief from being available to investors. Finally, we report on the passage of the Stamp Duty Land Tax (Temporary Relief) Bill through Parliament.
25 styczeń 2023 // Publication
This month our two-page guide looks at various topics including the: challenge to the Conduct of Employment Agencies and Employment Business (Amendment) Regulations 2022; Strikes (Minimum Service Levels) Bill; challenge to the Tesco Stores Ltd v USDAW decision; OTS policy paper on tax implications of hybrid and distance working; EU Proposal for Directive on pay transparency; Government consultation on calculating holiday entitlement; prospectus regime legislation; High Pay Centre’s High Pay Hour 2023; HMRC updated guidance on remuneration trusts.
19 styczeń 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 Royal Assent of the Finance Bill 2022-23. There have been some interesting cases on determining the date of transfer of goodwill from a partnership to a company, whether subsistence expenses were taxable, the pension scheme sanction charge on an unauthorised employer payment, and an appeal regarding interest on bad debt claims. We have also reported on the publication of the UK MDR regulations, and HMRC’s consultation on simplifying R&D tax reliefs.
12 styczeń 2023 // Publication
On December 29, 2022, the IRS and Treasury issued proposed regulations relating to the qualification of a real estate investment trust (“REIT”) or a registered investment company (“RIC”) as a domestically controlled qualified investment entity (the “Proposed Regulations”). The Proposed Regulations may impact sponsors and non-U.S. investors in real estate funds, private equity funds and other tax structures involving REITs.
5 styczeń 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 have covered an interesting case on when the duty to notify arises under the DOTAS regime. We have also reported on HMRC’s consultation on draft guidance on revisions to R&D tax reliefs, and the publication of draft legislation on the Electricity Generator Levy. Finally, we have covered the Office of Tax Simplification’s report on hybrid and distance working.
22 grudzień 2022 // 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 Chancellor’s announcement of the date for the Spring Budget 2023. We have covered regulations extending the IME to transactions in certain crypto-assets and amending certain NICs thresholds. We have reported on the EU Member States reaching an agreement to implement the EU Pillar 2 directive, and the OECD’s implementation package for Pillar 2. Finally, we have covered HMRC’s consultation on draft regulations on transfer pricing documentation measures.
21 grudzień 2022 // Publication
This month our two-page guide looks at a range of topics including: the EU directive for gender targets on boards adopted by the European Parliament; the Government’s response to the flexible working consultation; the end of the four-day working week trial; a review of the Senior Managers and Certification Regime; two more episodes of our Diversity Faculty podcast series; our online Directors’ Remuneration Report guide; EU market abuse rules changes; bonus cap removal and MRTs in public sector roles; Climate Transition Plan disclosure; and global share plans update.
15 grudzień 2022 // 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 Edinburgh Reforms to financial services, which include a consultation on the VAT treatment of fund management services, an expansion of the IME to include cryptoassets and changes to the REIT rules. There have been some interesting cases, including a CJEU decision on DAC6 notification obligations infringing legal professional privilege. We also cover HMRC’s Banking Code of Practice report and the latest OECD Pillar One consultation.
13 grudzień 2022 // Publication
On 18 November 2022, the Council of Ministers approved the 2022 Program Law (the “Draft Law”) introducing a number of changes to the existing tax treatment of copyright related income under Belgian tax law. This is a special personal income tax regime where income from copyright is taxed in the hands of the individual copyright holder at a flat rate (the “Copyright Tax Regime”). These changes have essentially been suggested in an effort to limit the budgetary impact of the existing legislation, as well as to put an end to the alleged tax abuse of the Copyright Tax Regime.