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Decisions to be made on UK CFC State aid challenge Now that they have had a chance to digest the decision in the EU State aid investigation into certain aspects of the UK CFC rules, affected taxpayers are asking a number of questions. Will the UK appeal? It would seem surprising if it did not - and we wou...

Exploring technological solutions for the Irish border post Brexit Over the last week or two there has been lots of debate about unnamed 'technological solutions' for avoiding a hard border in Ireland. So what are these mooted solutions? Firstly, we need to establish what this type of border is usually used for, taking ...

New UK securitisation regulations - Edinburgh reforms In this Article, Louis Kriechbaum discusses the new UK Securitisation Regulations and the Edinburgh Reforms. HM’s Treasury, the Prudential Regulation Authority (“PRA”) and the Financial Conduction Authority (“FCA”) have each...

Hargreaves in the Court of Appeal: A return to orthodoxy on withholding taxes? The Court of Appeal has dismissed Hargreaves’ appeal against the Upper Tribunal’s decision and determined that tax should have been withheld from interest paid on loans advanced to the group. The judgment provides taxpayers and their advisers ...

Asset Management Hot Topics - Spring 2024 Welcome to the Winter/Spring 2024 edition of our Asset Management - Hot Topics series. Many developments covered in this edition relate to the shape of the UK’s post-Brexit framework for financial services. An overarching theme is th...

Overseas supply chain risk – A change of approach from the English courts? In a positive move for corporates, the High Court’s decision in Limbu v Dyson indicates the English courts are now willing (and able) to decline to hear claims against UK companies concerning their overseas operations and supply chains in favour of ...

Tax and the City Review for October 2023 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider the draft legislation to enact the EU-derived exemption from 1.5% stamp taxes on the issuance and transfer of securities to a clearance service or depositary receipt issuer; and ...

Competition & Regulatory Newsletter: European Commission clears Microsoft/Activision Blizzard subject to conditions On 15 May 2023, the European Commission approved the proposed acquisition of Activision by Microsoft, subject to conditions. Following an in-depth review of the deal, the Commission concluded that the licensing commitments offered by Microsoft would fully...

Cooperation, dialogue, divergence: The future UK-EU relationship in financial services In this briefing, we consider the likely implications of the Memorandum of Understanding establishing a framework for financial services regulatory cooperation between the EU and the UK that was adopted by the European Commission and is now subject to pol...

Tax and the City Review for April 2023 Mike Lane and Zoe Andrews discuss the FTT’s decision in Muller (application of intangible fixed assets rules to an LLP), the UT’s decision in Prudential (interaction of VAT grouping and time of supply rules) and some Spring Finance Bill measur...