Corporate and commercial | 01 November 2011

In the run-up to the 2011 Budget, and subsequently, there have been numerous references in the media to the bank levy (the Levy). But what is it, how has it arisen and is it really relevant to in-house counsel, other than those individuals who work within banks? [Continue Reading]

Corporate & Commercial | 01 October 2011

Investment activities between the UK and Germany are substantial. However, until recently, taxpayers resident in these two countries have been encumbered by a rather outdated regime dealing with the avoidance of double taxation.

On 30 March 2010, Germany and the UK signed a new version of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital (the Convention), which will replace the convention dated 26 November 1964 (the 1964 Convention, amended 23 March 1970). In many respects, the Convention reflects the model double tax convention issued by the OECD (the OECD model). [Continue Reading]

Corporate & Commercial | 04 July 2011

Since its introduction in 1995, the Spanish holding companies’ regime, Entidades de Tenencia de Valores Extranjeros (ETVEs), has proven to be an attractive and competitive international tax planning scheme for multinational groups from the EU, US and, more recently, Asia (China and India), particularly with respect to investing in Latin America. [Continue Reading]

Corporate & Commercial | 04 June 2011

Law Decree No 225 of 29 December 2010 (the Decree), converted to Law No 10 of 26 February 2011, has drastically changed the Italian tax regime of domestic and Luxembourgish collective investment vehicles (CIVs), other than real estate investment funds. Before the amendments the CIVs were taxable at a rate of 12.5% on the accrued annual result and the distributions to investors were, in principle, exempt. Now the accrued result of the CIVs is taxable only in the hands of the investors on a cash basis. The new tax regime of the CIVs is in line with the Italian tax regime applicable to almost all EU/European Economic Area (EEA) CIVs that are distributed in Italy. [Continue Reading]

Corporate & Commercial | 04 May 2011

The Chancellor of the Exchequer, George Osborne, delivered his Budget on 23 March 2011, in which various tax amendments were announced. In his Budget speech, the Chancellor announced that two of the government’s ambitions for the British economy were to create the most competitive tax system in the G20 and to make the UK the best place in Europe to start, finance and grow a business. Consequently, many of the Budget announcements are viewed as being favourable to business. The most significant changes in relation to business and potential investors are summarised in this article. [Continue Reading]

Legal Briefing

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Corporate and commercial | 01 April 2011

Various corporate groups have recently relocated or announced that they are considering relocating their holding companies from the UK to places such as Switzerland and Ireland. Talk of tax moves has become common place. Does this mean the UK is an undesirable place to base a global corporate group’s operations? This article suggests that the UK may not be such a bleak place to be located, but each group must consider its own circumstances. [Continue Reading]

Legal Briefing

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Corporate and commercial | 01 February 2011

Continuing the recent trend of expanding the UK’s already extensive body of tax legislation, 2011 looks likely to be a busy year for the law makers. This article summarises the key tax changes that are set to take place over the next year.
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Corporate and commercial | 01 December 2010

In its June 2010 Budget the Government announced several proposals as part of a five-year plan to reform corporation tax, including a proposal to exempt foreign branch profits from corporation tax. This followed the previous government’s announcement in the 2009 Pre-Budget Report that it recognised foreign branch taxation as a ‘matter of growing importance’ and intended to engage with businesses to explore potential future rule changes. A discussion document setting out the proposal for such an exemption and key issues arising from it was published on 27 July 2010, alongside the reform of the Controlled Foreign Company (CFC) rules.

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