Cross-border: Tax

This note discusses the situations in which taxpayers can enter into advance pricing agreements, which allow them to agree transfer pricing issues with HMRC, and the procedure for entering into such agreements.

A practice note explaining where to find EU law content from a topic page.

An outline of the EU's comitology procedure (formerly regulatory procedure with scrutiny).

This note details the UK corporate residence rules and explains how you can decide whether a company is resident in the UK for UK tax purposes. It also examines how you can decide whether a non-UK resident company has a UK permanent establishment and how UK permanent establishments are taxed under UK law. In addition, this note describes how the right to tax a company's profits may be divided under a double tax treaty if a company is resident in two territories or is resident in one territory but has a permanent establishment in another.

A practice note about the controlled foreign companies regime introduced by the Finance Act 2012.

A discussion of tax issues that may arise when interest and royalties are paid between the UK and other countries.

A practice note outlining the key features of the "VAT package", which is a group of changes to the VAT rules for cross-border supplies of services that largely came into force on 1 January 2010. This note covers the changes to the place of supply rules, EC sales list reporting requirements and Eighth Directive refund claims.

This note is one of a series of notes on cross-border transactions and VAT and deals specifically with the VAT principles which apply to the supply of goods into the UK from a place outside the UK. For an introduction to the general VAT principles which apply to cross-border transactions, see Practice note, Cross-border transactions and VAT: an introduction. Industry-specific exceptions to the general principles and customs duties are outside the scope of this note.

A consideration of the tax treatment of derivative transactions for UK companies.

A practice note on the tax treatment of dividends.

This practice note provides an introduction to the purpose and interpretation of double tax treaties.

An outline of the EU legislative process and its interpretation in the UK.

A discussion of the UK tax issues that arise for multinational groups financing UK group members from outside the UK or financing non-UK group members from within the UK.

A discussion of the main tax issues relating to debt finance in the Cayman Islands, Jersey, Ireland, Luxembourg, the Netherlands and Belgium.

A practice note about measures to reform UK corporation tax in the following areas: Controlled foreign companies. Profits and losses of overseas branches. Intellectual property. Dividends received by companies. Interest paid by companies. International movement of capital (treasury consent).

This practice note explains the tax aspects of creating, acquiring and disposing of intellectual property (IP), cost-sharing arrangements, the research and development (R&D) tax incentives offered by the UK and other key jurisdictions and the tax issues to consider when establishing an IP holding company. It includes a comparison of the leading jurisdictions for locating an IP holding company.

This practice note provides an introduction to the various structures commonly used for investment funds (for example, limited partnerships, UK authorised unit trusts, UK open-ended investment companies, offshore trusts and offshore companies) and the importance of tax planning in this area. It also provides links to other, more detailed practice notes, each of which addresses the tax issues relating to a specific type of investment fund.

A practice note listing key forthcoming dates in 2012 for corporate tax practitioners.

This practice note examines the various tax issues that arise in relation to limited partnerships, including the tax treatment of partners and the tax consequences of changes in limited partnership interests.

This practice note examines the various tax issues that arise in respect of offshore companies and offshore unauthorised unit trusts. It also provides a summary of the main UK anti-avoidance provisions that need to be considered in relation to the tax treatment of UK investors investing in offshore funds.

This note outlines the EU's ordinary legislative procedure (formerly co-decision procedure) and its history.

A practice note on the mixed funds ordering rules introduced by the Finance Act 2008. NOTE: This resource is being reviewed in light of the 2013 Budget. For more information, see 2013 Budget: key private client tax announcements.

Following the announcement in the 2007 Pre-Budget Report that significant changes would be made to the tax rules governing residence and domicile from 6 April 2008, an avalanche of draft legislation, clarifications, amendments and guidance was published. Further amendments and changes were made as the bill progressed through parliament. In the light of this, we published this practice note to provide, in one place, an explanation of the key changes together with links to HMRC's guidance. However, following Royal Assent to the Finance Act 2008, all the changes relating to residence, domicile and related tax issues have been incorporated into Practice Note, Residence, ordinary residence and domicile: definitions and UK tax implications for individuals. THIS PRACTICE NOTE IS NO LONGER MAINTAINED.

This note contains links to practice notes covering: the meaning of "residence" and "ordinary residence" in the context of UK taxation; the meaning of "domicile" and the UK tax implications for individuals of these concepts.

This note explains what the Court of Justice of the European Union (formerly known as the European Court of Justice (ECJ)) is, why a reference would be made to it and who can make a reference. The note gives examples of questions which might be referred to the ECJ and sets out a brief summary of the procedure to be followed and the effect of a ruling by the ECJ on the question referred.

A practice note about the statutory residence test (SRT) for individuals that the government intends to introduce in the Finance Act 2013 (FA 2013). Following Royal Assent of FA 2013 (likely to be in July 2013), the SRT will determine whether an individual is UK resident for tax purposes for the tax years 2013-14 onwards. We would welcome subscribers' views on the practicalities of operating the SRT, see Your comments. NOTE: This practice note is being reviewed in light of the government amendments to Schedules 43 and 44 to the Finance Bill 2013 announced on 13 June 2013. For more information, see Private client tax legislation tracker 2012-13: Statutory residence test and Abolition of ordinary residence.

A document containing items formerly found in PLC Tax legislation trackers but that are now in force.

A document tracking the development of certain notable pieces of proposed new legislation relating to finance taxation.

A Q&A guide to tax on finance transactions in Hong Kong. This Q&A provides a high level overview of finance tax in Hong Kong and focuses on corporate lending and borrowing (including withholding tax requirements), bond issues, plant and machinery leasing, taxation of the borrower and lender when restructuring debt, and securitisations. This Q&A is part of the PLC multi-jurisdictional guide to tax. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

This Q&A provides country-specific commentary on Practice note, Tax: international joint ventures, and forms part of our international joint ventures transaction guide.

This Q&A provides country-specific commentary on Practice note, Tax: international joint ventures, and forms part of our international joint ventures transaction guide.

This Q&A provides country-specific commentary on Practice note, Tax: international joint ventures, and forms part of our international joint ventures transaction guide.

This Q&A provides country-specific commentary on Practice note, Tax: international joint ventures, and forms part of our international joint ventures transaction guide.

This Q&A provides country-specific commentary on Practice note, Tax: international joint ventures, and forms part of our international joint ventures transaction guide.

This Q&A provides country-specific commentary on Practice note, Tax: international joint ventures, and forms part of our international joint ventures transaction guide.

This Q&A provides country-specific commentary on Practice note, Tax: international joint ventures, and forms part of our international joint ventures transaction guide.

This Q&A provides country-specific commentary on Practice note, Tax: international joint ventures, and forms part of our international joint ventures transaction guide.

This Q&A provides country-specific commentary on Practice note, Tax: international joint ventures, and forms part of our international joint ventures transaction guide.

This Q&A provides country-specific commentary on Practice note, Tax: International Acquisitions, and forms part of our international acquisitions transaction guide.

This Q&A provides country-specific commentary on Practice note, Tax: international joint ventures, and forms part of our international joint ventures transaction guide.

This Q&A provides country-specific commentary on Practice note, Tax: International Acquisitions, and forms part of our international acquisitions transaction guide.

This Q&A provides country-specific commentary on Practice note, Tax: International Acquisitions, and forms part of our international acquisitions transaction guide.

This Q&A provides country-specific commentary on Practice note, Tax: International Acquisitions, and forms part of our international acquisitions transaction guide.

A note considering the UK corporation tax treatment of exchange gains and losses.

This Practice note examines the impact of the Treaty of Lisbon on the decision-making procedures and substantive policies of the European Union.

A discussion of the UK's thin capitalisation and transfer pricing rules in the context of cross-border transactions.

This note provides an overview of the UK/Switzerland tax co-operation agreement to tackle tax evasion by UK taxpayers holding funds in Swiss bank accounts. The agreement came into force on 1 January 2013. The note discusses the anonymous one-off payment to settle past tax liabilities, the withholding tax on income and capital gains going forward and the one-off withholding tax on death. It also looks at the requirements for disclosure as an alternative to these deductions, further protection in the agreement for HMRC (such as information requests) and options for UK residents with Swiss bank accounts. We would welcome subscribers' views on the practical implications of the agreement (see Your views). Note: this resource is being reviewed in the light of the 2013 Budget. For more information, see Legal update, 2013 Budget: key private client tax announcements.

This practice note examines the various tax issues that arise in respect of UK authorised and unauthorised unit trusts and UK open-ended investment companies. It considers the tax treatment of such funds and of their investors.