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Category Archives: UK
Double reasonableness test – narrowing GAAR in UK
Recent attempts to introduce a general anti-abuse rule (GAAR) in the UK have been long and not without some soul searching. The stoush is almost around the world because multinational companies are apparently skirting around their tax burden by casting an almost overpowering spell over most countries’ tax administrations. In the midst of all these shenanigans, the UK Government proposed a GAAR in its Finance Bill 2013. Hope were blown up that big companies could finally have their comeuppance. But, it was … Continue reading
Transfer pricing – OECD Model Tax Convention, commentaries and guidelines
The Tax Laws Amendment (Cross-Border Transfer Pricing) Bill (No. 1) 2012 now before Parliament seeks to introduce the use of OECD Model tax Convention and its commentaries and the transfer pricing guidelines, in the interpretation of international tax agreements as at 22 July 2010 , to the extent they are relevant. This inevitably poses the question whether it is prudent buy viagra online to limit the use of the commentaries and guidelines made up to 22 July 2010. and ignore … Continue reading
Using PE losses in UK
The Advocate General of the European Court of Justice (ECJ) has issued an opinion on the case of HRMC v. Philips Electronics UK Ltd (C-18/11, 19 April 2012). Briefly the facts in the case are: Parent company was established in the Netherlands. Entities in the group included a UK company and a permanent establishment of the Dutch company in the UK The UK authorities disallowed setting off loses of the PE against the income of the UK company The UK … Continue reading
UK non-doms: an efficient CFC carve-out?
The recent budget delivered in the UK proposes to raise the tax payable by non-UK domiciled taxpayers. Under the measures non-UK domiciled taxpayers who have been UK residents for 12 or more years will be subject to a charge of 50,000 pounds, a large increase from the current level of 30,000. The scheme when first introduced by the Finance Act 2008 guaranteed remittance based taxation in case of individuals who have been in the UK for more than 7 of … Continue reading
Taxing the have nots
The wall in Berlin is nearly two decades down, the debilitating cold war is off the table and ageing Fidel in Cuba is the last of the incorrigible antagonists. Even he is reported to have backtracked. No more pontificating on the merits of ideologies once thought eternal. Happy days are here again. It’s time to relax in front of the telly and relish the culinary prowess of the y-gen on Junior Master Chef. The message is getting through to the … Continue reading
