A new double tax agreement between the UK and Austria was signed on 23 October 2018. Subject to both countries having completed their parliamentary procedures and exchanged diplomatic notes, it will to come into force for the fiscal year beginning...
The Government will apply income tax to offshore businesses making offshore royalty payments in respect of intangible property used to generate UK sales. This will apply from 6 April 2019. The charge will apply unless the entity is UK resident or...
The CJEU has issued a decision in case C-553/16 (TTL EOOD) holding that interest charged by the Bulgarian authorities on unpaid withholding tax on cross border leasing payments to unconnected parties was contrary to EU law in the circumstances. The...
A draft statutory instrument has been issued to put into effect the UK’s choices for adopting the OECD’s multilateral instrument (MLI). Purpose of the MLI By way of a reminder, the multilateral convention is intended as a swift mechanism to...
The First tier Tribunal has held that Hargreaves Lansdown Asset Management Ltd’s (HL’s) payment of a loyalty bonus to investors was not an annual payment. As a consequence there was no requirement to withhold income tax from the payment. The...
Background In the joined cases of Deister Holding AG, formerly Traxx Investments NV (C‑504/16) and Juhler Holding A/S (C‑613/16), concerning the different tax treatment of non-resident EU investors in German companies compared to German resident investors, the CJEU has held...
Background The UK government has been reviewing corporate tax and the digital economy (see its position paper on the matter). That paper proposed a staged approach to bringing digital businesses, such as online markets and social media platforms, within the...
What’s the issue? HM Treasury issued a position paper on corporate tax and the digital economy on 22 November. It highlights deficiencies in the international tax framework , where value is generated by digital means from the presence of users...
Back in 2010, Eyjafjallajökull erupted and spread its volcanic ash across western and northern Europe. Perhaps Philip Hammond has been using this as his inspiration in looking to spread the UK tax net as wide as possible in his search...
The CJEU has released a decision (C-6/16 “Eqiom & Enka”) confirming that the French rules on applying withholding tax (WHT) to dividends of a French company to another EU group company outside France, where the group is owned by a...
A recent decision by the Court of Justice of the European Union (CJEU) and a recent note of European Commission infringement proceedings could result in the ability of businesses to reclaim French contributions tax and French withholding tax respectively. Background...
Claudio Ranieri (the ex-Leicester City FC manager, for those who have never heard of him) has often been referred to as the “Tinkerman” because of the changes he would constantly make to some of the football teams he managed. Will...
At this year’s Budget on 16 March 2016, it was announced that a number of changes would be made to extend the scope of withholding tax on royalties. There are three key areas of change: A targeted anti-avoidance rule denying...
One of the key developments announced at the Budget on 16 March 2016 concerned provisions to widen the withholding obligation in respect of payments of royalties. This is aimed at multinationals which have arrangements in place to reduce taxable profits...
Today’s blog is from Dick van Sprundel, Assistant Professor International and European Tax Law at the Erasmus University Rotterdam plus International Tax Partner Mazars Netherlands. On 4 March 2016, the Dutch Supreme Court delivered its final decisions in X, Miljoen...
New withholding tax exemption applies from 1 January 2016 Finance Act 2015 Section 23 introduced new Section 888A into ITA 2007 Pt. 15, Ch. 3 providing an exception for ‘qualifying private placements’ from the general requirement to deduct tax...
Recently the First Tier Tribunal covered a case on deduction of UK withholding tax from interest paid by a UK resident individual on borrowings from a Manx Trust (Perrin). The FTT decided that the interest arose in the UK thus...
The CJEU has ruled that no withholding tax should be deducted from dividends paid by Polish companies to a US based investment fund (Emerging Markets Series of DFA Investment Trust Co). The decision will be of wider relevance, not merely...
The Government’s consultation about taxing non-residents on their gains derived from UK-residential property goes further than simply extending UK CGT to make non-residents taxable on disposals of UK residential property in the same way as UK residents. The new rules...
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