10 Tax Rankings
Chambers 2023
9 Tax Rankings
Legal 500 2023
Band 1 Tax
Chambers 2023, Europe-wide
28 มิถุนายน 2567 // Publication
The RNG and SAF Capital Markets Summit, presented by Infocast and held on June 19, 2024, featured a distinguished panel of heavy hitters in the world of SAF (“sustainable aviation fuel”), moderated by Linklaters tax partner Michael Rodgers, who focuses on structuring, planning and negotiating infrastructure and renewable energy transactions. The panel highlighted the current state and future of the SAF market with a sense of where the market currently is, where it needs to go and what needs to happen in order to get there.
24 มิถุนายน 2567 // Publication
Our guide includes: New employment legislation; Change in FCA approach to diversity and inclusion; Contract workers have no claim against end user for discrimination (CoA); Employer did not have knowledge of employee’s disability diagnosed after employment ended (EAT); MyHMCTS portal: Change to how ET1s should be submitted; Potential review of the EU prudential regime for investment firms; ESMA recommends pan-European share plan; EU CRD6 / CRR3 published; Listing Rules LTIPs compliance; and General election manifestos proposals.
20 มิถุนายน 2567 // Publication
UK Tax News is a round-up of recent UK tax developments relevant to large businesses.
In this week’s edition, we cover interesting cases on whether borrowing as part of an acquisition structure has an unallowable purpose, the application of the IR35 rules to a TV presenter in light of the Court of Appeal decision in Atholl House, the meaning of “extraction of value” in the remittance rules, and the striking out of HMRC’s application for a tax-related penalty of £14m due to defects. We also report on new OECD guidance on certain aspects of Pillar One and Pillar Two.
13 มิถุนายน 2567 // 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 an interesting case on whether an Irish taxpayer was precluded from obtaining treaty relief on account of an anti-abuse provision in the UK-Ireland double tax treaty. We also report on a case on whether bank transfers from offshore bank accounts and the use of offshore credit cards for UK purchases constituted remittances.
6 มิถุนายน 2567 // 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 (No. 2) Act 2024. There have been some interesting cases on the recovery of input VAT on professional services on a sale of shares, whether a VAT assessment was made within the applicable time limits, and third party access to written submissions to the tribunal. We have also covered recent developments relating to the UK-Belarus double tax treaty and the publication of HMRC’s updated standard for agents.
30 พฤษภาคม 2567 // Publication
Our guide includes: EAT decision on when deductions from wages form part of a “series”; US FTC issues final rule banning most worker non-competes; Platform Work Directive adopted by European Parliament; consultation on further TUPE reforms; UK Solvency II reform; EU banks will have to consider ESG risks; scope of the Takeover Code to be narrowed; loans made from a remuneration trust found to be ‘disguised remuneration’; new HMRC share schemes bulletin; and the government consults on increasing "medium sized" company employee threshold.
28 พฤษภาคม 2567 // Publication
In response to challenges in the implementation of Section 871(m) of the Internal Revenue Code and comments from the financial industry, the US Internal Revenue Service (“IRS”) has issued a series of notices, providing for transitional rules. On May 22, 2024, the IRS published Notice 2024-44, which is the latest notice extending the application of certain transitional rules (the “Notice”).
23 พฤษภาคม 2567 // 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 an interesting case on the application of the transactions in securities regime to a share buyback undertaken to crystallise EIS relief. We also cover HMRC’s publication of a notice and guidance on registering for Pillar 2 top-up taxes, the synthesised text of the MLI and UK-Liechtenstein double tax treaty, and the joint declaration on the conclusion of negotiation on the UK-Peru double tax treaty.
22 พฤษภาคม 2567 // Publication
On 27 December 2023, the "Act Implementing Council Directive (EU) 2022/2523 to Ensure Global Minimum Taxation and Other Accompanying Measures" (Minimum Tax Act, Mindeststeuergesetz or MinStG) was published in the German Federal Law Gazette. With this law, Germany has transposed the internationally agreed requirements for implementing a global minimum taxation (GloBE) into national law.
16 พฤษภาคม 2567 // 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 พฤษภาคม 2567 // 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 พฤษภาคม 2567 // 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 เมษายน 2567 // 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 เมษายน 2567 // 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 เมษายน 2567 // 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 เมษายน 2567 // 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 เมษายน 2567 // 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 มีนาคม 2567 // 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.