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Corporate Governance HMRC

Goodwin

UK Employee Share Plans: 6th of July HMRC Reporting Deadline

Goodwin on

Businesses that award shares, options or other securities to UK employees, directors or officer holders need to be aware of the July 6 deadline to submit an Employment Related Securities (ERS) annual return to HM Revenue &...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Consults on Draft Legislation on Transfer Pricing, Permanent Establishments and Diverted Profits Tax

On 28 April 2025, HM Revenue and Customs (HMRC) proposed significant reforms to the UK’s transfer pricing and permanent establishment (PE) rules, and a repeal of the diverted profits tax, bringing that regime within UK...more

NAVEX

The UK’s New Whistleblower Reward Scheme: A Turning Point for Tax Accountability

NAVEX on

In a landmark move, HM Revenue & Customs (HMRC) has announced plans to launch a formal whistleblower award program modelled on the highly successful U.S. Internal Revenue Service (IRS) Whistleblower Program. This initiative...more

Skadden, Arps, Slate, Meagher & Flom LLP

Members of UK LLPs and Significant Influence: Commentary on HMRC v. BlueCrest Capital Management (UK) LLP

On January 17, 2025, the UK Court of Appeal (Court) released its decision on whether certain members of BlueCrest Capital Management (UK) LLP (BlueCrest) should be taxed as employees under the UK “salaried members” rules (the...more

Latham & Watkins LLP

Recent Developments for UK PLCs - September 2024

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On 13 August 2024, the Financial Reporting Council (FRC), as part of a cross-regulatory group comprising the FCA, Companies House, HMRC and Charity Commission for England and Wales, published a discussion paper on the future...more

Proskauer - Tax Talks

UK Supreme Court confirms no deduction for expenses related to share and asset sale

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On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of...more

Proskauer Rose LLP

UK Tax Round Up - March 2024

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Welcome to March’s edition of our UK Tax Round Up. This month has seen a number of interesting cases covering a range of issues, from the deductibility of costs against employment income to the place of effective management...more

J.S. Held

The Diverted Profits Tax & Royalty Withholding Tax: Impacts on Intellectual Property Licenses and Transactions

J.S. Held on

The Diverted Profits Tax (DPT) has been a significant area of focus for taxpayers and tax authorities in the UK and Australia. The tax targets specific situations in which taxable profits are alleged to have been “diverted”...more

White & Case LLP

The HMRC Restructuring Plan Challenges: Lessons Learned from GAS, Nasmyth and Prezzo

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Earlier this year, the English Court refused to sanction two Part 26A restructuring plans ("RPs") which sought to bind HMRC, the UK tax authority, into restructurings via "cross-class cram down". (See "Restructuring Plans...more

Hogan Lovells

UK government plans to introduce a re-domiciliation regime

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On 27 October 2021, HM Treasury, BEIS and HMRC published a consultation paper seeking views on proposals for a UK re-domiciliation regime under which foreign-incorporated companies could change their place of incorporation to...more

Proskauer Rose LLP

UK Tax Round Up - June 2019

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Guernsey SPV not resident in the UK - In Development Securities plc and others v HMRC, the Upper Tribunal (UT) has overturned the prior discussion of the First-tier Tribunal (FTT) in favour of the taxpayer in an important...more

Proskauer Rose LLP

UK Tax Round Up - July 2017

Proskauer Rose LLP on

UK Tax News and Developments - Conservative legislative agenda set out in Queen's Speech - Following the UK general election on 8 June 2017, at which the Conservative party won the largest number of seats but lost its...more

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