United Kingdom – New DTA with China effective
The Income Tax Treaty between China and the United Kingdom entered into force on 13 December 2013. The new tax treaty replaces the 1984 income tax treaty between the United Kingdom and China and is effective beginning 2014. The new treaty provides
See MoreUnited Kingdom – Foreign income dividend claims
In a recent ruling, the England and Wales Court of Appeal issued a decision concerning the time limits for making foreign income dividend (FID) claims and “Manninen claims” in a test case for the FID and Tax Credit Group Litigation. The Court of
See MoreUnited Kingdom – Derivative contracts and anti-avoidance legislation
On 23 January 2014, draft legislation amending the rules for derivative contracts was updated by adding an anti-avoidance provision which disregards debits and credits arising from arrangements to transfer profits between group companies. The
See MoreRevised China-United Kingdom DTA enters into force
An income tax treaty between China and the United Kingdom entered into force on 13 December 2013, and is effective from 2014. The new treaty replaces the 1984 treaty between the two countries and provides for lower rates of dividend and royalties
See MoreUnited Kingdom: Dispute resolution, CFC financing, investment “white list”
HM Revenue & Customs have updated some key documents regarding resolution of tax disputes, and have provided new guidance on CFCs. The dispute resolution documents are the Code of Governance for resolving tax disputes; and Commentary on the
See MoreUK-Netherlands: Protocol to treaty enters into force
The Protocol amending the Double Taxation Agreement (DTA) between the UK and the Netherlands, signed in London on 12 June 2013, has entered into force on 13 December 2013. The Protocol is effective in the UK for any assessment year beginning on or
See MoreUK: Coalition Partner indicates preference for Income Tax Allowance Increases
The UK Deputy Prime Minister has said that the personal allowance could be increased beyond the target GBP 10,000 in April 2014 if the Government were to abandon “pet projects” on tax and focus on on a single goal of a high allowance
See MoreUK Chancellor Envisions Permanent Tax Cuts
The UK Chancellor of the Exchequer has reiterated the government’s commitment to continue cutting taxes, especially through spending cuts, and without any extra borrowing. He cited the cuts in income taxes and freezing fuel duty, and the increase
See MoreUK: Increase in 2014 intrastat reporting thresholds
The United Kingdom has updated the annual reporting thresholds for Intrastat declarations from 1 January 2014. For arrivals (import of goods from other EU member states) the threshold will rise from GBP600,000 to GBP1,200,000 per annum; and for
See MoreUnited Kingdom and Iceland sign a DTA
The United Kingdom and Iceland signed a double taxation agreement (DTA) on December 17,
See MoreJoining of Six More Countries with the Tax Information Exchange Pilot of G5
UK, France, Germany, Spain, and Italy (the G5) planed for a multilateral program in April which was based on the automatic exchange of tax information. Participants of 37 jurisdictions have expressed their intention to join. Luxembourg,
See MoreJapan – Signing of the Protocol Amending Tax Convention with the United Kingdom
Japan and the United Kingdom Signing of the Protocol Amending Tax Convention with the United Kingdom on 17 December 2013 which amending the current income tax treaty between the two countries. Before it enters into force the Protocol must be
See MoreTax treaty between India and United Kingdom – Indian decision on taxability of fees for technical services
The Indian Income Tax Appellate Tribunal (ITAT) issued its decision on 31 May 2013 in the case of Veeda Clinical Research Private Limited (ITA 1406/Ahd/2009) that the provision of market awareness and development in-house training services to an
See MoreUnited Kingdom – Changes of tax refund-procedure not compatible with EU law
The Court of Justice for the European Union (CJEU) issued a judgment on 12 December 2013 concluding that EU law precludes UK measures effect of which is to deprive taxpayers and that happened without notice and retroactively. It was focused on
See MoreUK: Shares issued under interest free loan agreement are taxable income
On 15 November 2013, it was reported that the United Kingdom First Tier Tribunal found that the receipt of shares from a borrower in an interest free loan agreement between United Kingdom companies was taxable income. The case in which this decision
See MoreUnited Kingdom: UK High Court decision on portfolio dividend tax
UK High Court decision concerns the portfolio dividend tax (holdings of less than 10%) under the previous tax law which provided double tax relief for foreign withholding taxes paid on the dividends and no relief for any underlying tax. UK has moved
See MoreTax Devolution process for Wales has been confirmed by the UK Government
The UK Prime Minister has confirmed in a press release on 7 November 2013 that the Government intends to devolve the power to set Landfill Tax and Stamp Duty rates in Wales, and to hold a referendum on devolving the income tax rate. It was announced
See MoreA ‘FATCA’-type Agreement has been signed by Cayman and the UK
A bilateral governmental agreement has been signed by The Cayman Islands with the United Kingdom on November 05, 2013 which set the foundation for the automatic exchange of financial information about UK taxpayers who hold accounts in the Cayman
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