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13 November 2014

UK Patent Box: UK and Germany compromise on preferential IP regimes

By Angela Browning This week saw UK and Germany agree a joint proposal to advance the negotiations on new rules for preferential Intellectual Property (IP) regimes within the G20/OECD Base Erosion and Profit Shifting (BEPS) Project. These proposals will impact the future of the UK Patent Box and other similar...

05 November 2014

We don’t need new digital taxes, we need an international tax system fit for the Digital Age

By John Steveni The ways in which global businesses are taxed has been on the front pages more in the last couple of years than during the whole of the rest of my career combined. There’s a perception that international businesses, particularly those of a more virtual nature, are paying...

VAT recovery by holding companies - another cost to business?

By Michael Bailey HMRC's new Revenue and Customs Brief 32/14, which updates the internal guidance on VAT recovery by holding companies, sets out a number of potentially onerous conditions to be fulfilled. HMRC policy looks to apply normal VAT principles of a taxable business, which buys in goods and services...

31 October 2014

Scotland Act 2012 is coming down the Tartan track anyway…who knew!

By Gwyneth Scholefield Post referendum we’re still on a bit of a roller coaster ride. As we now know it was a No vote, but there were changes in place with regards to the Scottish Rate of Income tax through the Scotland Act 2012 which many appear to have overlooked....

28 October 2014

Substantially higher tax bills for international businesses with branch structures

By Michael Bailey A recent European Court decision in the Skandia America Corporation (Skandia) case is likely to change the VAT liability of head office to branch charges where there’s a VAT group in place. The risk for businesses is that international structures including VAT groups may, in the future,...

17 October 2014

Irish Budget 2015 - some key outcomes

By Roz Burke The Irish budget was delivered this week (14 October). Here are some key highlights from the announcement: Residence test to be amended such that Irish incorporated companies will be held to be tax resident in Ireland unless they are tax resident in another territory by virtue of...

15 October 2014

Tax Transparent Funds take off

By Hazell Hallam & Roy Lonergan Until recently, the UK lacked a tax-transparent pooling vehicle which prevented many UK-domiciled funds from winning a share of the European market. This also acted as a barrier to the UK being the largest asset management centre in Europe. In 2013 regulations were introduced...

14 October 2014

Country-by-country reporting: What’s your plan?

By Stuart MacPherson The idea of country-by-country reporting – where multinationals report the payments they make to governments (including taxes), in each country in which they operate – has steadily gained momentum over the past few years. Companies in the financial services sector and extractive industries have already been grappling...

10 October 2014

Find out all you need to know about Know Your Customer from HMRC

By Paul Dixon A lot has been written about HM Revenue & Customs' (HMRC) new approach to PAYE risk and now our clients have the chance to hear directly from HMRC about what it all means. Neil Rollason, HMRC’s strategic lead for Employer Compliance in HMRC’s Large Business team, has...

30 September 2014

When people trump capital

By Michael Cooper 50 years ago it wasn’t difficult to pinpoint where a company created its value – it tended to be where its machinery was located. Today, in the world of complex multinationals, continual innovation and service companies, it’s rather more difficult to tell. That’s why people are suddenly...