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Global Investigations Bulletin (June 2021) Our latest Global Investigations Bulletin for June 2021 is now available. This month, we take a look at the European Public Prosecutor’s Office, set out the latest news in global investigations and enforcement actions, and provide key horizon scanning...
Tax and the City Review for May 2021 Mike Lane and Zoe Andrews look at the decisions in Euromoney and M Group Holdings Limited; amendments to the Finance Bill; and updated HMRC stamp taxes guidance on submitting electronically.
Discovery of the Tooth Few tax cases manage to elicit such intractable feelings of crossness in me as the saga of HMRC v Tooth which has come to an end with the Supreme Court judgment of 14 May 2021. I am astonished that a point which was, frankly, utterly obvious had to go all...
From CCCTB to BEFIT: the European Commission's plan to future-proof taxation The Commission's Communication on Business Taxation for the 21st century sets out reams of important tax policy announcements, whilst evidencing what seems like a growing enthusiasm for acronyms on this side of the Atlantic.
Supreme Court confirms (again) that Ramsay is a principle of statutory construction We all love a good Ramsay case.  Particularly one from the Supreme Court which does not upset the apple cart and require a re-learning of principles!  And one in which HMRC is not involved makes for an interesting change.
Hong Kong Private Equity: 0% tax rate for carried interest - legislation enacted Hong Kong introduces 0% tax rate for carried interest paid by qualifying Hong Kong private equity funds to their managers, effective from 1 April 2020.
Global Investigations Bulletin (May 2021) Our latest Global Investigations Bulletin for May 2021 is now available. This month, we review corporate convictions for bribery in the UK, set out the latest news in global investigations and enforcement actions, and provide key horizon scanning updates...
Tax impact of European Commission’s draft foreign subsidies Regulation Under the European Commission’s draft Regulation for a new regime to address the impact of subsidies from non-EU countries on trade within the EU published on 5 May 2021, tax concessions, reliefs and credits granted by the UK or other non-EU...
The cautionary tale of Mr Bostan Khan On 30 April 2021 the Court of Appeal handed down its unanimous judgment in Bostan Khan v HMRC. As tax cases go, it is neither the biggest in terms of amounts of tax at stake (except, one assumes, from the perspective of poor Mr Khan) nor the most complex....
Tax and the City Review for April 2021 Mike Lane and Zoe Andrews look at the legislation bringing in the new financial institution notice (FIN); Tax Day measures; the consultation on the reform of the taxation of securitisation companies; and the second consultation on notification of...
The long-awaited Euromoney decision has finally appeared. But is it right? For much of last year, Euromoney was paired with Blackrock as a potentially ground-breaking case focusing on a statutory purpose test. Both have now resulted in victory for the taxpayer, through the agency of Kevin Prosser QC, and both show yet...
Taxing Tokens The last few weeks have seen a number of cryptoasset milestones reach the mainstream press - in that context it is perhaps a tad disappointing that HMRC's cryptoassets manual, which it updated recently, still seems in places to use the terms "...
Global Investigations Bulletin (April 2021) Our latest Global Investigations Bulletin for April 2021 is now available. This month, we discuss the Financial Conduct Authority’s initiation of criminal proceedings against NatWest for breaches of the 2007 Money Laundering Regulations. We also set out...
Tax Day! The UK Government has, in its own words, published "more than 30 tax updates, consultations and documents in a move to strengthen policymaking and modernise UK tax system" as part of the tax policies and consultations update on 23 March 2021,...
Tax and the City Review for March 2021 Mike Lane and Zoe Andrews look at Budget 2021 and the review of bank taxation in particular; the publication by the OECD of the International Compliance Assurance Programme handbook; and the CA decision in Eastern Power Networks.