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  • Milestone Briefing Note – UK Partnerships

    Over the past year we’ve worked on a number cross border transactions (inbound / outbound investment, reorganisations etc) in conjunction with tax advisers from various parts of the world. A common feature has been the interest in using a UK partnership (in one guise or another). This briefing note highlights the main features and tax treatment of all UK partnerships.

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    February 24, 2016 Posted by:

  • Miles Dean

    GOOGLEGATE 2.0!

    As a follow up to our ‘Googlegate’ blog post from Tuesday this week we have been asked by various readers of the blog, including journalists, whether we think HMRC should publish details of the ‘deal’ done with Google. Essentially, the issue is that of balancing Google’s interest in avoiding confidential information reaching the public domain whilst pacifying claims that a ‘sweetheart deal’ has been done.

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    January 29, 2016 Posted by:

  • Miles Dean

    GoogleGate!

    Once again it’s everywhere: Google’s tax affairs are in the newspapers, on the TV and radio. It certainly makes for great headlines – Google, the US technology giant, has agreed to pay HMRC £130m in back taxes and bear a greater tax burden in the future. Opinions vary from those who claim that the extra £130m is a derisory figure compared with the company’s turnover, to those who see it as only right to pay what is provided by law and nothing more.

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    January 26, 2016 Posted by:

  • Miles Dean

    Join us at the Transnational Tax Network Conference in Hong Kong

    We’re pleased to announce that both Miles and Zoe will be speaking at the Transnational Tax Network conference at Hong Kong’s Park Lane Hotel on Monday 9th February.

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    February 5, 2015 Posted by:

  • Rozi Ellis

    Don’t Get Clawed by the Russian Bear – Introducing the New CFC Rules

    The Russian Federation marked the end of an unpredictable 2014 by tightening its regulations on offshore companies in an attempt to protect its tax base and prevent outflows of capital.

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    February 4, 2015 Posted by:

  • Miles Dean

    Puerto Rico Tax Exemptions Acts

    In an attempt to stimulate domestic economic growth, the government of Puerto Rico enacted two laws (in 2012) that provide generous tax incentives for individuals and businesses. While such Acts are not unusual for smaller island states, these two Acts are unique in that they potentially provide US citizens with a significant tax advantage.

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    January 8, 2015 Posted by:

  • Miles Dean

    An Open Response to the Evening Standard Re STARBUCKS

    In yesterday’s Evening Standard (1 December 2014), Starbucks new UK Chief Exec was interviewed and quoted as saying “There is nothing abnormal about the way we are run”. The Standard then ran an editorial piece on the interview that I referred to as “astonishingly ignorant” in a tweet on the way home.

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    December 2, 2014 Posted by:

  • Antony Barrier

    The Cosmetic Warriors case: tax “avoidance” nihilists clutching at straws?

    The High Court case of Cosmetic Warriors Ltd & anor v Amazon.co.uk Ltd & anor [2014] EWHC 181 (Ch) has been latched onto by various commentators as further evidence of Amazon’s artificial tax avoidance structure. This is, in our view, wholly incorrect.

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    November 25, 2014 Posted by:

  • Rozi Ellis

    German Patent Box Regime?

    The European debate on Research and Development taxation took an interesting turn last month when reports emerged that the German finance ministry is considering a response to growing industry lobby for a domestic ‘patent box’ style tax reduction.

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    October 24, 2014 Posted by:

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