10 Tax Rankings
Chambers 2023
9 Tax Rankings
Legal 500 2023
Band 1 Tax
Chambers 2023, Europe-wide
16 May 2024 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition, we report on Finance Bill’s progress through Parliament. We also cover cases on the tax treatment of revocable option agreements, the capital gains tax treatment of a transfer of a beneficial (and not legal) interest, and the application of the unallowable purpose rule to a reorganisation of group debt. Finally, we cover HMRC’s publication of changes to the VAT treatment of voluntary carbon credits.
8 May 2024 // Publication
On April 24, 2024, the IRS and the U.S. Department of Treasury (“Treasury”) issued final regulations relating to the qualification of a real estate investment trust (“REIT”) or a registered investment company (“RIC”) as a domestically controlled qualified investment entity (the “Final Regulations”). The Final Regulations finalize, with changes, the proposed regulations issued on December 29, 2022 (the “Proposed Regulations”) and may impact sponsors and non-U.S. investors in real estate funds, private equity funds and other tax structures involving REITs.
2 May 2024 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition, we report on cases on the deductibility of provisions for future pensions payments, the application of certain grandfathering rules to carried interest arrangements and the proper approach to the IR35 rules. The OECD has also published consolidated commentary on Pillar 2, and HMRC has published a manual of VAT tertiary legislation.
25 April 2024 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition, we report on the progress of the Finance Bill through parliament. There have also been a series of interesting cases relating to owner-managed businesses (concerning capital gains tax loss relief, the application of the Ramsay principle to a conditional loan award and the disguised remuneration rules). Finally, we have covered a case concerning the meaning of beneficial ownership and whether interest payable under a series of short terms loans was subject to WHT.
24 April 2024 // Publication
Our guide includes: ET case on AI racial discrimination settles; Vento bands increased; government to legislate to prevent NDA misuse; EAT confirms decision-maker must have knowledge of detail of worker’s whistleblowing disclosure to be liable; SC confirms that workers striking during working hours are not protected from detriment short of dismissal; director’s remuneration report rules simplified; 2024 PIRC Shareholder Voting Guidelines published; government consults on the PISCES system for trading unlisted shares; and Listing Rules reform.
18 April 2024 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition, we report on some interesting cases on the tax treatment of debt instruments issued alongside warrants, whether an intra-group financing had an unallowable purpose, the VAT treatment of continuous intra-group supplies invoiced after the supplier left the group, and the AG’s opinion on whether certain aspects of the UK CFC rules constitute State Aid. We also cover HMRC’s new guidance on the 1.5% exemption and HMRC and HM Treasury’s consultation on the RIF regulations.
3 April 2024 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition, we report on some interesting cases on the tax treatment of distributions paid out of the share premium of a Jersey company, the availability of SEIS relief, and whether certain arrangements put in place in lieu of a payment under an indemnity constituted a remittance of foreign gains. We have also covered the government’s decision to introduce an anti-abuse rule in relation to the Pillar 2 transitional Country-by-Country Reporting safe harbour.
3 April 2024 // Publication
The Infocast Solar + Wind Finance & Investment Summit, held on March 12, 2024, featured a distinguished panel, moderated by Linklaters' tax partner Michael Rodgers, to discuss the current trends and future outlook of the tax equity market. The panel included Jack Cargas of Bank of America, Bryan Didier of Monarch Private Capital, Ben Jacoby of Paragon Energy Capital, Rubiao Song of JP Morgan, and Colin Witherspoon of US Bank.
28 March 2024 // Deal
Linklaters advised OmnigenicsAI Corp, a precision medicine company incubated by Bioceres Group PLC, on a definitive Business Combination Agreement with APx Acquisition Corp. I (NASDAQ: APXI), a publicly traded special purpose acquisition company, and MultiplAI Health Ltd, a UK-based AI-enabled preventive medicine company, that, upon closing, would result in OmnigenicsAI becoming a publicly listed company. The deal values OmnigenicsAI and MultiplAI at a combined enterprise value of approximately $340 million at signing, and the transaction is expected to close mid-year, subject to the approval of APx's shareholders and other customary closing conditions.
27 March 2024 // Publication
On Friday, the IRS and Treasury Department issued Notice 2024-30 (“the Notice”) pertaining to the energy community “bonus” credit addition to the Section 48 and 48E investment tax credit and Section 45 and 45Y production tax credit (the “EC Bonus”). The Notice serves to amend two prior notices announcing the Treasury Department’s intent to issue proposed regulations relating to the EC Bonus, each of which provide specifics as to how taxpayers may qualify for the same.
26 March 2024 // Publication
The Belgian Government agreed to submit tax proposals to Parliament that are aimed to boost the competitiveness of Belgian industries. Hereafter we discuss three proposals which might have a (positive) impact on your business.
21 March 2024 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition, we report on the publication of the Finance (No.2) Bill 2023-24 and its passage through Parliament. We have covered the publication of regulations amending the Construction Industry Scheme, regulations introducing a new IR35 set-off mechanism and a consultation on draft regulations mandating certain extra information in income tax self-assessment returns. We also report on the passage of the National Insurance Contributions reduction bill through Parliament.
20 March 2024 // Publication
Our guide includes: Spring Budget roundup; increased statutory rates and limits for ET claims; FTSE Women Leaders Review; EHRC guidance on menopause in the workplace; changes to redundancy protection, flexible working, national minimum wage, and annual leave from April 2024; new carer’s leave right; EAT decision on religion and belief discrimination; IA update re Remuneration Principles, PLSA 2024 voting guidance; EBA Q&A on valuing deferred pay; global share plans updates; and proposed TRS exemptions for smaller trusts.
14 March 2024 // Publication
After 218 years, dating back to the Napoleonic era, we are on track to a modernised Belgian Civil Code. The extensive Civil Code reform aims to suit the needs of the modern society by codifying or modernising backbone rules of the laws of property, evidence, obligation and contracts.
7 March 2024 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition, we report on the Spring Budget delivered by the Chancellor. We have covered some interesting cases on the application of the Ramsay principle to defeat a dividend replacement avoidance scheme and on the trading status of a company for the purposes of entrepreneurs’ relief. Finally, we have reported on regulations made on NICs limits and thresholds for 2024-25 and the publication of updates to the Stamp Taxes manual for changes to the 1.5% charge.
1 March 2024 // Publication
The Antwerp Tribunal of First Instance has clarified that payments to tax havens are tax-deductible if they are declared in the corporate tax return, stem from genuine transactions, and are not made through "artificial constructions" created to evade Belgian taxes (as opposed to foreign taxes).
29 February 2024 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition, we report on the enactment of the Finance Act 2024. We also report on an update on the transition from digital services tax to Pillar One and the OECD report on Amount B of Pillar One. We have covered HMRC’s new approach to providing clearance on termination payments, and its consultations on the Tax Administration Framework.
22 February 2024 // Publication
Our guide includes: consultation to re-introduce ET and EAT fees; EAT decision on age discrimination following LTIP changes; EAT decision on whistleblowing protection not extending to external applicants; paternity leave changes; draft Code of Practice on Dismissal and Re-engagement consultation response; New UK Corporate Governance Code and board Guidance; Ofwat consults on performance-related pay restrictions; ISS proxy policy and voting guidelines; FCA survey on non-financial misconduct; EBA Q&A and MRT deferred pay; new UK prospectus rules; and global share plans update.