Pearse Trust Blog
UK employers currently contemplating or negotiating employee termination agreements as well as employees anticipating receipt of termination payments should be aware of changes to the relevant tax regime which will apply for the 2018-19 tax year onwards.
The Canadian Limited Partnership (‘LP’) is increasingly used as a vehicle for the conduct of international transactions and the holding of investments.
Notwithstanding the fact that the Canadian LP does not have separate legal status (unlike for example the Scottish LP), the LP is an attractive holding arrangement for foreign investors with portfolios or other investments outside Canada.
Irrespective of the absence of legal personality, where a Canadian LP holds US portfolio investments, it may elect corporate tax treatment under US tax law while still maintaining its transparent taxation status under Canadian law.Read More
The UK tax authority, HM Revenue and Customs (HMRC), has issued draft guidance on how Northern Ireland’s separate corporate rate will be administered.
As a constituent nation of the United Kingdom, Northern Ireland is generally subject to UK law. Therefore, companies are subject to the UK's 19% corporate tax rate (for 2017/18).Read More
The United Kingdom Government recently concluded a public consultation on a new measure intended to tackle tax base erosion and profit shifting (BEPS) and ensure that companies operating in the digital economy are taxed “appropriately.”
The measure in question is intended to extend the UK withholding tax regime to certain outbound royalty payments connected with the exploitation of IP rights in the UK. However, while other jurisdictions have since proposed similar types of measures, tax practitioners in the UK have cast doubt over how the tax can be applied.Read More
The jury is still out on whether the OECD’s base erosion and profit shifting project is improving the international tax framework, or making it even more uncertain. However, if the OECD is correct then one aspect of the BEPS plan is having a positive effect on international business and commerce by reducing the time and resources taxpayers spend to resolve double taxation disputes, with this improvement largely attributable to a process known as the Mutual Agreement Procedure, or MAP.Read More
Although not compulsory, the appointment of an appropriate Trust Protector is becoming increasingly relevant as the application of trusts for estate planning and asset protection evolves.Read More
The UK's Office of Tax Simplification (OTS) has been tasked with investigating options for reform of the UK's inheritance tax.
While unlikely to be a root-and-branch review of this much-maligned and often complex tax, tax experts do suggest that the sort of changes to be explored could be a step in the right direction.Read More