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Aktuelle eAlerts

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  12/12/2024

  United Kingdom

  UK Tax Disputes Digest (Winter 2024)

  Welcome to the Winter 2024 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for heads of tax, finance directors, general counsel and other in-house professionals.As with previous editions, we have seen a continued increase in HMRC activity across various areas. Both individual and corporate taxpayers would be well-advised to check their tax position as soon as possible to prepare for any potential HMRC investigation into their tax affairs.In this edition, we look at just a few of these developments, including in relation...

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  12/12/2024

  Belgium

  Class 23 insurance: Opportunity for non-resident insurers to pursue tax relief in Belgium

  GB FR

  On 7 November 2024, the Court of Justice of the European Union (CJEU) handed down a crucial ruling concerning the discriminatory taxation of dividends received by non-resident insurers in the Netherlands. This ruling could have significant implications for non-resident insurers in Belgium.ContextA UK insurance company offering “unit-linked insurance plans” in the Netherlands was subject to a 15% withholding tax on dividends received in the Netherlands. The company challenged the withholding tax on the grounds that Dutch insurance companies engaged in similar activities were not taxed...

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  30/10/2024

  United Kingdom

  Autumn Budget 2024 – key tax announcements

  The 2024 Autumn Budget has been one of the most anticipated fiscal events in recent years. Not only is it a post-election Budget – the Labour Party’s first Budget in almost fifteen years – but the length of the period that has elapsed since the election, the Government’s discovery of a £22bn “black hole” in the public finances, and the broad commitments contained in Labour’s manifesto have all contributed to a lengthy period of intense speculation.Recent confirmation from the Chancellor that tax increases were a certainty, combined with the Government’s...

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  09/09/2024

  United Kingdom

  UK Tax Disputes Digest (Summer 2024)

  Welcome to the Summer 2024 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for heads of tax, finance directors, general counsel and other in-house professionals.As with previous editions, we have seen a continued increase in HMRC activity across various areas. Both individual and corporate taxpayers would be well-advised to check their tax position as soon as possible to prepare for any potential HMRC investigation into their tax affairs.In this edition, we look at just a few of these developments, including the latest...

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  11/03/2024

  United Kingdom

  Welcome amendment to the Construction Industry Scheme regulations as they relate to payments between landlord and tenants

  At the Autumn Statement 2023, the government announced amendments to the Income Tax (Construction Industry Scheme) Regulations 2005 (the Regulations), including removing certain payments between landlord and tenants from the scope of the Construction Industry Scheme (the CIS).Those amendments will come into force on 6 April 2024, having been laid before the House of Commons on 8 March 2024.What was the concern?The CIS was originally introduced to protect revenue in relation to the construction sector, with significant non-compliance suspected as a result of cash-in-hand payments. The CIS requires...

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  06/03/2024

  United Kingdom

  Spring Budget 2024 – key tax announcements

  Against the backdrop of an election (probably) later this year, the Chancellor was evidently feeling the pressure to make tax announcements that would find favour with the electorate, whilst constrained by the economic environment. Warning that further tax cuts can only be funded by growing the economy and making the state more efficient, the emphasis was on fiscal responsibility and increasing resilience to future shocks. The reduction in employee NICs – matching that in the Autumn Statement - had been so heavily rumoured in the immediate run up to budget day that it was hardly a surprise. ...

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