"UK Supreme Court: Legal Advice Privilege Relates to Lawyers’ Advice Only"
Summary - In an eagerly awaited decision of the U.K. Supreme Court in the case of R (on the Application of Prudential plc and Another) v. Special Commissioner of Income Tax and Another, [2013] UKSC 1,...
View Article"HMRC Turns Up the Pressure on UK LLPs"
Following the announcement in Budget 2013, HM Revenue & Customs (HMRC) issued a consultation document on May 20, 2013 that focuses on two areas of partnership taxation where HMRC perceive...
View Article"International Taxation – OECD Reboot for the 21st Century"
Introduction - Following on its February 2013 report on Addressing Base Erosion and Profit Shifting (BEPS), the Organisation for Economic Co-operation and Development (OECD) has now released an...
View Article"European Council’s Lawyers Opine That Proposed EU Financial Transaction Tax...
The European Council Legal Service has issued an opinion that seriously questions the legal validity of the European Commission’s proposals for a financial transaction tax (FTT). The opinion finds that...
View Article"UK Government to Strengthen Code of Practice on Taxation for Banks"
On October 11, 2013, the U.K. Government announced three key changes to the Code of Practice on Taxation for Banks (the Code): - A bank that breaches the Code could be publicly named. However, before...
View Article"Taxpayer Naming – The Future of UK Tax Compliance?"
As part of Autumn Statement 2013, HM Revenue & Customs (HMRC) has today publicly named the banks that have newly adopted or readopted the Code of Practice on Taxation for Banks (the Code)....By:...
View Article"Base Erosion and Profit Shifting: Key UK Issues"
Six months have elapsed since the Organisation for Economic Co-operation and Development (OECD) released its 15-point action plan to address Base Erosion and Profit Shifting (BEPS). During this time,...
View Article"OECD Releases Global Standard for Automatic Exchange of FATCA-Type Information"
As part of a push for greater transparency, the Organization for Economic Cooperation and Development (OECD) released on February 13, 2014, a Common Reporting Standard (CRS) for Automatic Exchange of...
View Article"OECD Outlines Plans to Prevent Double-Tax Treaty Abuse"
On March 14, 2014, the Organisation for Economic Co-operation and Development (OECD) published a discussion draft report on preventing double-tax treaty abuse (the Treaty Report). The OECD supplemented...
View Article"OECD Draft Report: The Digital Economy and Its Tax Challenges"
On March 24, 2014, the Organisation for Economic Co-operation and Development (OECD) published a discussion draft report on the tax challenges facing the digital economy (the DE Report). This draft...
View Article"European Court Rejects UK’s Financial Transaction Tax Challenge"
U.K.’s challenge to the proposed financial transaction tax (FTT), while recognizing that the U.K.’s challenge was precautionary — and possibly premature. The U.K. was challenging the European Council’s...
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