European Tax

While HMRC’s consultation on modernising the distributions rules looks only at income tax (and not corporation tax) treatment, this post...

Amongst the more (generally) positive proposed changes being considered as part of HMRC's consultation on modernising the distributions...

Never a dull day in Tax! HMRC’s consultation on modernising the taxation of distributions and repayments of capital from companies, which...

The receipt or threat of an information notice from HMRC under Schedule 36 FA 2008 is commonly the point many tax departments reach for...

Can a taxpayer rely on a treaty exemption on the disposal of a shareholding if the gain is not taxed in the taxpayer’s state of...

In a decision of significance for the secondary debt market, the Court of Appeal in Burlington has unanimously dismissed HMRC’s appeal....

When is capital expenditure "on the provision of plant” for the purposes of section 11 Capital Allowances Act 2001? This was the question...

There are many places in the UK tax legislation where deeming provisions are employed in order to apply the tax rules to particular...

On 5 January 2026, the OECD published the Side-by-Side (SbS) Package. This package complements the OECD Inclusive Framework's model rules...