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Tax Matters Digest: 9 May 2024 Edition
To go straight to the articles in the latest edition please scroll down and expand the section/s below that are of interest to you. For a preview of these articles, read the introduction to the latest edition from Sharon Baynham here:
It has been a quiet couple of weeks in the tax-world and so this edition is an eclectic mix of articles covering some niche areas.
Our headline article highlights an analysis published by our US firm on two sets of proposed regulations released by the US Treasury department and Internal Revenue Service in relation to the 1 percent Excise tax that can apply on repurchases of corporate stocks after 31 December 2022.
At the OECD, a consolidated commentary has been released that incorporates the original March 2022 commentary on the Pillar Two rules with the three sets of Administrative Guidance issued during 2023 to deal with a number of issues. The OECD has also updated its examples to take into account the Administrative Guidance.
For those of you that like to chew the fat on the nuances of case law, we have an interesting analysis of recent case law dealing with whether expenses in relation to employee remuneration were incurred ‘wholly and exclusively’ for the purposes of a trade. We also draw out key findings in Holding and Another v HMRC, a case dealing with ‘mixed use’ in the SDLT regime and what the courts look to in finding the dividing line between residential and mixed use properties.
A recent article by KPMG Law highlights the risks for public bodies of the UK’s Subsidy Control Act 2022 on the Teckal company arrangements.
Finally, we include a link to Tim Sarsons’ latest International Tax Review for April as published in Tax Journal. And we have our usual round-up of VAT cases, other news and international developments.
US stock repurchase excise tax: proposed regulations
KPMG US initial analysis of the proposed regulations on the US stock repurchase excise tax
OECD releases consolidated commentary on GloBE Model Rules
Previously published commentary and guidance on the interpretation and application of the GloBE Rules has been consolidated into one volume
When is an expense incurred wholly and exclusively for trade purposes?
Two recent Upper Tribunal decisions act as a useful reminder of some core aspects of the 'wholly and exclusively' rule
Stamp Duty Land Tax (SDLT): No mixed messages for mixed use
Holding & Anor v HMRC continues a trend, with the key takeaway being the ‘use’ in mixed use.
Navigating Subsidy Control: Unveiling the Risks for ‘Teckal’ Companies
A recent article from KPMG Law looks at the impact of the UK Subsidy Control Act 2022 for public authorities who use ‘Teckal’ companies
International tax review for April 2024
Includes further guidance on the new 1 percent US excise tax and European Parliament adoption of an opinion on the FASTER Directive
Indirect Tax Weekly Talking Points – 1 May 2024
This week’s edition looks at VAT cases from the UK and Europe, as well as two Advocate General opinions
When is an expense incurred wholly and exclusively for trade purposes?
Two recent Upper Tribunal decisions act as a useful reminder of some core aspects of the 'wholly and exclusively' rule
When is an expense incurred wholly and exclusively for trade purposes?
Two recent Upper Tribunal decisions act as a useful reminder of some core aspects of the 'wholly and exclusively' rule
Stamp Duty Land Tax (SDLT): No mixed messages for mixed use
Holding & Anor v HMRC continues a trend, with the key takeaway being the ‘use’ in mixed use.
Other news in brief
- Sunset clause extensions for Freeport and Investment Zones now legislated
- Final regulations published on the use of trade losses in the event of transfers of business by building societies
- HMRC guidance highlighting common areas of error in claims for capital allowances on plant or machinery
- Non-compliant employers named in latest NMW Government list
