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  • Miles Dean

    MTN May

    With our Practice Manager, Jamie, safely married and back from his honeymoon we have a professional celebration this month. Rozi Ellis gave a webinar on the new UK corporate offence of Failure to Prevent Facilitation of Tax Evasion for our good friends TPA Global. Her webinar was so well received she has been asked to deliver it in person to Transnational Taxation Network’s New York conference next week. She goes with our best wishes (and shopping list for Big Apple souvenirs).

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    May 17, 2018 Posted by:

  • Miles Dean

    Formula 1—White Noise around Tax Structure?

    Formula 1 receiving a tax refund of circa 180 million pounds earlier this year from the U.K. tax authority could only ever be deemed one thing —a “sweetheart deal.”

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    May 16, 2018 Posted by:

  • Rozi Ellis

    The Digital Economy: The New Pandora’s Box of International Tax

    The European Commission (EC) has been flexing its political muscle in cross-border tax, this time the target placed firmly on digital businesses. On 21 March 2018 the EC published proposals for two Council Directives on the Fair Taxation of the Digital Economy. The proposals are designed to reshape the tax codes of Member States’ (MS) so that revenues (not profits) generated by online businesses are subject to tax. A principle of corporate taxation is that…

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    May 15, 2018 Posted by:

  • Andrew Parkes

    Central management and control in the UK

    One of the best known judicial pronouncements in tax, possibly because it has been in use for over 100 years, is the one by Lord Loreburn in De Beers Consolidated Mines Ltd v Howe (5 TC 198) relating to deciding where a company is resident: ‘A company resides … where its real business is carried on … and the real business is carried on where the central management and control actually abides.’

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    May 14, 2018 Posted by:

  • Geoff Hippert

    The EU reportable arrangement rules for intermediaries

    The EU recently introduced a set of reportable tax arrangement rules (‘the EU rules’) inspired by Action 12 of the OECD’s base erosion and profit shifting (BEPS) project on mandatory reporting regimes in an international context.

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    May 10, 2018 Posted by:

  • Miles Dean

    MTN April

    As we approach the end of March, so we say a brief farewell to our Practice Manager, Jamie, who is getting married later today. We wish him and his beautiful bride, Catherine, nothing but the best. In the grand tradition of weddings, we offer something old, something new, something borrowed and something blue for our newsletter this month.

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    April 12, 2018 Posted by:

  • Miles Dean

    Wayne Rooney scores tax own goal

    Wayne Rooney’s potential tax exposure arising from the failed Invicta 43 tax scheme is the latest example of sports stars and celebrities getting their fingers burnt as a result of investing in highly artificial, highly complex tax arrangements that have potentially been mis-sold. In recent times, we have seen many such high profile scandals; Jimmy Carr was branded “morally wrong” by then PM, David Cameron, for using the K2 tax scheme, Chris Moyles, the radio…

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  • Miles Dean

    Dutch withholding tax

    The past The Dutch aren’t big on withholding taxes (WHTs), even less than the UK. There’s no WHT on royalties and WHT on interest is limited to loans that work like equity (so the interest is a proxy for dividends). However, unlike the UK there is WHT on dividends. The Dutch dividend WHT is set at 15% which is reduced or eliminated by an applicable double tax treaty or the Parent Subsidiary Directive. The present…

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    March 16, 2018 Posted by:

  • Miles Dean

    Tax affairs don’t lie, as Shakira knows

    Pop star Shakira has recently been charged with tax fraud by the Spanish tax authorities.

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  • Rozi Ellis

    The UK’s Register of Trusts

    Overview On 26 June 2017, the UK amended the reporting obligations placed on the trustees of certain UK and non-UK trusts. The new rules are the UK’s implementation of the EU’s Fourth Anti-Money Laundering Directive (4MLD) and aim to tackle the increasing demands of global transparency. The registration and reporting requirements will impact a vast number of trustees and individuals who are involved in trust arrangements. The legislation is contained within The Money Laundering, Terrorist…

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    February 14, 2018 Posted by: