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EU Blacklist Updated on 20 February 2024 – No New Jurisdictions Added and Bahamas, Belize, Seychelles and Turks and Caicos removed

Aron Joy — Tue, 27 Feb 2024 20:29:57 +0000

On 20 February 2024 the EU published an update to its so-called “Blacklist” of jurisdictions that are not cooperative for tax purposes and “Grey List” of cooperative jurisdictions that have not yet fully met their commitments to comply with tax good governance criteria. Whilst various jurisdictions have been removed from the lists, no new jurisdictions

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Upper Tribunal Gives Judgment in M Group Holdings Limited – Oh, What a Diff’rence a Day (or Month) Makes

Erica Rees — Mon, 27 Nov 2023 14:25:06 +0000

The Upper Tribunal’s recent decision in M Group Holdings Limited v HMRC [2023] UKUT 00213 (TCC), concerning the availability of the substantial shareholding exemption (“SSE”), serves as a useful reminder to heed any applicable “bright line” requirements when planning to avail of tax exemptions and reliefs. Background M Group Holdings Limited (“MGH”) had historically traded

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UK AUTUMN STATEMENT 2023: TAX UPDATE

Aron Joy — Wed, 22 Nov 2023 18:48:02 +0000

On 22 November 2023, Chancellor Jeremy Hunt delivered his Autumn Statement, potentially the last such statement to precede the next UK general election.Despite mounting speculation over the past few days, there were no rabbits in the Chancellor’s hat, and today’s announcements were broadly in keeping with expectations. The headline items included the announcement that the current full expensing policy for businesses will be made permanent – a move which the Chancellor heralded as “the biggest business tax cut in modern British history” – and various changes to National Insurance contributions (NICs), including a reduction of the main rate and the abolition of Class 2 NICs for self-employed individuals.

Member States Update EU list of Non-Cooperative Tax Jurisdictions

Aron Joy — Fri, 20 Oct 2023 11:36:51 +0000

On 17 October 2023, the EU published the conclusions of its bi-annual review of the list of non-cooperative jurisdictions for tax purposes (the “EU Blacklist”) and the state of play document (the “EU Grey List”, which monitors jurisdictions that do not yet comply with all international tax standards but have committed to implementing reforms). The

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QAHCs and Credit Funds – Update on Regulatory Registration Requirements

Aron Joy — Mon, 25 Sep 2023 14:25:12 +0000

In April 2022, the UK introduced the Qualifying Asset Holding Company (“QAHC”) regime. The regime is intended to entice investment funds, and certain other investors, to establish their holding structures in the UK as opposed to, for example, Luxembourg or Ireland. To this end, a range of tax reliefs are available to companies that qualify for and elect into the regime, such as no withholding tax on interest paid by a QAHC, the ability to use profit participating instruments to offset returns on debt investments and a blanket UK corporation tax exemption for gains on the sale of (most) shares. QAHCs can also be useful, in particular, for funds whose managers are based in the UK who may have difficulty in establishing or demonstrating sufficient substance in an overseas holding company, which may result in issues with local substance requirements in underlying investment jurisdictions or the proposed Anti-Tax Avoidance Directive III, if it is enacted.