Tax insights

The 2025 Dutch tax classification of the Brazilian FIP

The Dutch tax classification system for non-Dutch entities will undergo significant changes as of 1 January 2025.

Global | Publication | December 19, 2024

“Unallowable purpose” following Blackrock, JTI and Kwik-Fit – is the law now settled?

UK tax legislation now includes numerous anti-avoidance tests which rely on the classic “unallowable purpose” formulation. We have seen the courts consider these in a wide range of circumstances. Many of these cases considered the rules included in the loan relationship regime but these decisions have application to many other targeted anti-avoidance rules of this type.

United Kingdom | Publication | November 18, 2024

Has the Budget finally levelled the playing field for UK Islamic finance?

Cricket players will tell you that whether a pitch is easy to bat on is not dictated by how much the balls bounce or turn, but rather, whether they do so consistently.

United Kingdom | Publication | November 15, 2024

Autumn Budget 2024: filling the “black hole”?

In the run up to the Budget the overwhelming call from business was for certainty and stability to enable long-term strategic decisions to be made and investment confidence to build.

United Kingdom | Publication | October 30, 2024

The end of the non-dom regime in the United Kingdom

The non-domicile (Non-Dom) status has been a distinctive characteristic of the United Kingdom (UK) tax system for many years, offering a favorable regime for certain individuals.

Global | Publication | October 07, 2024

When does the buyer of corporate debt lose tax treaty benefits?

In this In Practice article, the authors consider the Upper Tier Tribunal's decision in HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) which looked at whether the principal purpose of a transaction was to obtain treaty benefits.

United Kingdom | Publication | October 01, 2024

Pillar 2: Understanding its exemption for dividends and profit distributions

As of 1 January 2024, the Income Inclusion Rule (IIR) of the OECD Pillar 2 proposal will impose an additional tax on the ultimate parent company of a group if a foreign subsidiary is effectively taxed below 15%.

Global | External | June 01, 2024

Spring Budget 2024: an election year

This was an election year budget with the focus on personal taxes and quiet on the corporate tax side. Key personal tax measures had largely been trailed: the 2% reduction to the main rate of class 1 employee National Insurance contributions (NICs) and class 4 NICs and reform of the regime for non-domiciled individuals.

United Kingdom | Publication | March 26, 2024