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MDR/DAC 6 Update

Akash Mehta — Wed, 05 Jan 2022 18:56:48 +0000

On 30 November 2021, the U.K. government published a draft of new disclosable arrangements regulations, setting out the U.K.’s post-Brexit mandatory disclosure regime based on the framework established by the Organisation for Economic Co-operation and Development (the OECD) (the MDR Regulations). As we reported in December 2020, the scope of reporting in the U.K. under

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DAC6: Significantly Limited Scope in the UK post-Brexit

Oliver Walker — Thu, 31 Dec 2020 18:29:14 +0000

A piece of good news on which to end the year and start the next – the UK Government has published regulations dramatically reducing the scope of DAC6 (the EU Mandatory Disclosure Regime) in the UK as part of the Brexit deal package/post transition arrangements. In short, the effect seems to be that DAC6 will,

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Brexit & Tax Treaties: U.K. Investors May Lose Treaty Benefits With Respect to U.S. Investments

Devon Bodoh — Fri, 04 Dec 2020 21:32:28 +0000

The withdrawal of the United Kingdom (“U.K.”) from the European Union (“E.U.”) may impact certain cross-border organizational structures. We have previously considered some of those U.K. tax impacts in our post “Brexit and Tax: An Uncertain Future”. The points considered in that previous post continue to be relevant to cross-border structures involving the U.K. and

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Brexit and Tax: An Uncertain Future

Oliver Walker — Mon, 03 Feb 2020 11:21:53 +0000

The signing of the Withdrawal Agreement between the UK and the EU has avoided an immediate “no deal” Brexit and provided some clarity on relations with the EU in the short term. Once the UK exited at 11 pm on 31 January 2020, the UK and EU entered a “transition period” until 31 December 2020

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Perspectives: A Review of Current Legal Issues and Trends Looking Ahead to 2017

Oliver Walker — Thu, 27 Oct 2016 13:39:57 +0000

Although the EU referendum, and the various (tax and non-tax) implications for business arising out of the UK’s decision to leave the EU, has somewhat dominated the news for much of this year, another important development which has garnered rather less attention has been the proliferation of proposed changes to the domestic tax code. While

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A New Creed for the Tax Deed: The Impact of Market Trends

Oliver Walker — Thu, 15 Sep 2016 17:09:57 +0000

Most advisers will agree that the primary purpose of the tax deed is to allocate risk of unexpected tax exposure between the buyer(s) on the one hand, and the seller(s) on the other. This tends to mean that the seller will usually assume tax risk up to a certain date, such as the date on

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UK Tax Update: It’s Not All About Brexit!

Oliver Walker — Mon, 15 Aug 2016 12:46:14 +0000

There has rightly been a great deal of attention paid to the UK’s decision to leave the EU and what that may mean from a business (including tax) perspective. However, until the UK comes closer to leaving the EU (which is unlikely to be for at least two more years) Brexit is not expected to

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