Tax

News

HMRC appoints interim GC after Aitken’s departure

HMRC has named in-house lawyer David Bunting to replace Gill Aitken as director general of the solicitor’s office and legal services group on an interim basis. Bunting will report to HMRC chief executive Jon Thompson from 1 July while an open recruitment process is conducted to find Aitken’s permanent replacement. Bunting is expected to step […]

A picture of David Green QC who worked at the Serious Fraud Office, to illustrate The Lawyer Hot 100 Career Quiz with David Green QC career

Green QC, David – Serious Fraud Office

A tumultuous 2017 for the Serious Fraud Office (SFO) provided new opportunities to shine for director David Green QC. In his last full year in charge of the body, critics and admirers alike have cited his more “muscular” approach to litigation as a sign of the body’s ongoing success. Securing the future of the SFO […]

Analysis

US and UK flags: Laterals help US firms in London grow

Top 50 US firms in London: the firms dominating the $5bn market

This is an executive summary of The Lawyer’s US Top 50 Firms in London 2018 report  This is the second year The Lawyer has tracked the financial performance of the 50 largest US firms in the UK (primarily London). This data is not available in any other publication. Not only is it the work of […]

Featured Briefings

Switzerland: revised version of corporate tax reform

On 7 June 2018, the Swiss Council of States  issued its revised version for a corporate tax reform. It is based on the government’s proposal issued in March 2017. The purpose of this new proposal is to set the basis for new rules on Swiss corporate taxation (the last proposal having been rejected in a […]

Angola – general state budget for 2018

This briefing highlights the following tax provisions: The 10% Special Contribution on Current Invisible Foreign Exchange Transactions, applicable to payments related with foreign technical assistance and management contracts, was extended for 2018 (applicable to management services and foreign technical assistance service contracts executed under Presidential Decree no. 273/11, 27 October 2011)…

Input VAT recovery on fueling costs at stake?

Which party is to be considered the buyer of fuel and entitled to a VAT recovery? This question is now to be answered by the European Court of Justice. The answer could have far-reaching consequences for the automotive practice…

The Geneva ICO guide – heading towards a Crypto Lake?

By Hubertus Hillerström, Fouad G. Sayegh and Yacine Rezki The Canton of Geneva has published a guide on Initial Coin Offerings (ICOs) on 28 May 2018 in view of attracting more ICO initiators to the region and strengthening Switzerland’s leading position in this field by adding a «Crypto Lake» hub to the already well-established Crypto Valley between […]

Legislative proposal changing the Dutch tax consolidation regime

On 6 June 2018, the Dutch Ministry of Finance published a legislative proposal to change the Dutch tax consolidation regime. Based on the proposal, several provisions included in the Dutch corporate income tax act (CITA) and the Dutch dividend withholding tax act (WHTA) must be applied as if the Dutch tax consolidation regime does not apply. […]

Tax changes proposed for oil and gas companies in the Dutch North Sea

The Minister of Economic Affairs and Climate Policy (hereinafter: ‘the Minister’) submitted a letter (in Dutch only) to Parliament on 30 May 2018 on the safety (risks) of natural gas production from the ‘small fields’ in the Netherlands in relation to the energy transition. In this letter, the Minister also announced his intention to change the current […]

Austria: Mining cryptocurrencies as a permanent establishment

The taxation of cryptocurrency transactions is a hot topic. The Austrian Ministry of Finance recently issued an interesting ruling outlining when mining for cryptocurrencies in Austria by a non-resident taxpayer may trigger a permanent establishment. Income tax treatment of cryptocurrencies In general, capital gains from the sale of cryptocurrency units held as business assets and […]

HMRC loses in specie contribution claim before the FTT

By Patrick Shee Self-Invested Personal Pensions, or SIPPs, have been under HMRC’s microscope for a number of years, but in a recent decision the First Tier Tax Tribunal (FTT) ruled against HMRC, finding that Relief at Source (RAS) for non-cash or in-specie contributions should be given to individuals. In Sippchoice Limited v HMRC [2018] UKFTT 12 the […]

Investing in Sao Tome and Principe

To promote private-sector growth and to improve the business environment in the country, São Tomé and Príncipe has implemented a series of legislative measures that establish favourable conditions for foreign investment. The main measures adopted that are of particular interest to investors include approval of the new São Tomé and Príncipe Investment Code and the […]

Changes to Portuguese inheritance law

Under the current Portuguese law, the surviving spouse is the heir of the deceased spouse, except if they are legally or administratively separated. In order to change this «mandatory capacity» of the spouse, the Socialist Party presented a Draft Law (no. 781/XII) on 20 February 2018 which would allow couples planning to marry to determine […]

Angolan extraordinary tax and exchange amnesty rules

According to the news published in various media sources, a draft law that establishes a framework for an extraordinary tax and exchange regularisation programme (Regime Extraordinário de Regularização Tributária e Cambial – referred to here by its Portuguese initials, “RERTC”) is awaiting approval by the Angolan authorities. In the meantime, the draft law has been […]

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