Tax insights

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

Global Minimum Tax Rate – its impact on the world of aviation

There has been much commentary recently about the OECD’s proposal for countries to introduce a global minimum tax rate.

Global | Publication | January 24, 2024

Update on the VAT treatment of directors’ fees

On 21 December 2023, the Court of Justice of the European Union (CJEU) rendered a decision (case C 288/22 TP vs. Administration de l'enregistrement, des domaines et de la TVA) implying that directors’ fees should not be subject to Value Added Tax (VAT). This breakthrough decision overrides the established position of the Luxembourg VAT authorities and notably the Circular N°781, issued on 30 September 2016, which stated that directors’ fees were indeed subject to VAT as board members are carrying out an independent economic activity. It may also have implications elsewhere in the EU.

Global | Publication | January 08, 2024

UK - Luxembourg double tax treaty: Ratified by both Luxembourg and UK particular significance for UK real estate holding structures

The United Kingdom and Luxembourg signed an updated double tax convention and protocol (DTT) in July 2022.This has now been ratified by both the UK and Luxembourg, and as such, it will become effective for UK income and capital gains tax purposes in April 2024 and 1 January 2024 for income withheld at source.

Global | Publication | December 14, 2023