UCITS and Taxation


Book Description

This book examines the taxation of Undertakings for the Collective Investment in Transferable Securities (UCITS) in Austria, Germany, the Netherlands, and the United Kingdom. It analyses the tax consequences of the cross-border trade in units of UCITS for unitholders residing in the countries examined. It also features recommendations to remove the tax advantages and disadvantages that occur in cross-border trading.




Wealth Management Planning


Book Description

Wealth Management Planning addresses the major UK tax issues affecting wealth management planning for both the UK domiciled and non-UK domiciled individual. It explains, with numerous worked practical examples, the principles underpinning the three main taxes: income tax; capital gains tax; and inheritance tax. It is aimed at those involved in providing advice in the field of wealth management planning including solicitors, accountants, financial planners, private bankers, trustees, students of tax and law and the layman seeking in depth knowledge. The recent Finance Acts 2006 and 2008, in particular, have modified significantly the tax rules in key areas applicable to wealth management planning. These new tax rules are all addressed in detail in this book and include the pre and post Finance Act 2006 inheritance tax treatment of trusts; the new post Finance Act 2008 residence rules; and the new Finance Act 2008 rules applicable to non-domiciled individuals and the tax treatment of off shore trusts. In view of the increasingly international nature of wealth management planning the book attempts to place the UK tax rules in an international context addressing such issues as: the role of wills in the international arena; the implications of the EU; the suitability of off shore financial centres; and the role and use of double taxation agreements. Appendices bring together useful material produced by HMRC and a detailed bibliography for the interested reader is also included. “ This book gives comprehensive coverage to the complicated subject of taxation for Financial Planners. It will be very valuable to all those Financial Planners who wish to extend their learning and reference and desire to meet the needs of clients”. NICK CANN, CHIEF EXECUTIVE OF THE INSTITUTE OF FINANCIAL PLANNING. “ In this book, Malcolm Finney presents a comprehensive summary of the UK tax rules in straightforward language and with many practical examples. It is a notable achievement to put incomprehensible tax legislation into such readily understandable terms; anyone advising on wealth management will find this to be an invaluable guide to the subject”. MALCOLM GUNN, CONSULTANT, SQUIRE, SANDERS & DEMPSEY “ The author demonstrates considerable skill in explaining complicated tax rules in a manner that makes them easy to assimilate and understand. The book contains Chapter summaries, useful Appendices and numerous worked examples, which provide a very clear, helpful explanation of some difficult tax rules. The book’s contents cover wide areas of the tax system, and yet provide sufficient technical depth to be a valuable point of reference for those involved in wealth management and financial planning”. MARK McLAUGHLIN, MARK McLAUGHLIN ASSOCIATES, MANAGING EDITOR OF TAXATIONWEB “ A valuable new text explaining the tax treatment applicable to financial planning products and strategies for UK domiciled persons (UK resident or expats) and non domiciled UK residents. This book will be of interest to a wide readership ranging from students of law and tax, the interested layman seeking in depth knowledge and professionals including solicitors, accountants, financial planners, private bankers and trustees. Malcolm is to be commended on distilling a vast amount of detailed material into a logical and well ordered framework”. ANDREW PENNEY, MANAGING DIRECTOR, ROTHSCHILD TRUST CORPORATION LTD “ Malcolm Finney’s book is stimulating, innovative and refreshingly practical. Anyone wanting either a high-level understanding of tax principles involved in wealth management or a deeper insight should read this book”. JACOB RIGG, HEAD OF POLICY, SOCIETY OF TRUST AND ESTATE PRACTITIONERS, ST




The Political Economy of Corporation Tax


Book Description

Excellent technical writing on corporation tax abounds, but it tends to be inaccessible to public lawyers, political theorists and political economists. Although recent years have seen not only an explosion in public law scholarship but also a reawakening of interest in interpretative political theory and political economy, the potential of these perspectives to illuminate the corporation tax debate has remained unexplored. In this important work, John Snape seeks to reconcile these disparate strands of scholarship and to contribute to a new way of understanding and conceptualising the reform of the law relating to corporate taxation. Drawing on important developments in public law scholarship, the study combines elements of political theory and political economy. It advances a new interpretation of corporation tax law as an instrument of rule, through the maximisation of a nation's economic potential. Snape shows how corporate taxation belongs at the centre of any discussion of economic globalisation, not only because of the potential of national tax systems to influence inward investment decisions but also because of the potential of those decisions to shape the public interest that those tax systems might embody. Following public law and politics models, the book looks afresh at the impact of Britain's political institutions, of the processes of its representative government and of the theory that moulds and orders the values that the corporation tax code contains. This is a timely exploration of cutting-edge issues of public policy.










Taxation of Company Reorganisations


Book Description

Taxation of Company Reorganisations, Sixth Edition is an essential reference source for tax advisers which covers the basic rules of corporation tax and capital gains, reorganisations, share exchanges and other deemed reorganisations, reconstructions, mergers, demergers and branch incorporations, as well as cross-border transactions. Written by authors with more than fifty years' experience of dealing with clients from small owner-managed businesses to multinational corporate groups, this title includes guidance on the full range of corporate transactions and is applicable to a wide number of organisations. While there is comprehensive coverage of the technical and theoretical meaning of the legislation, the authors have also drawn on their vast practical experience, derived from many years of transaction-based work. This Sixth Edition has been brought fully up to date with recent Finance Acts including FA 2019 and the proposals for FA 2020 that were published in July 2019. It has been reviewed for company and European law and has been updated in relation to the following: - Changes to substantial shareholding exemptions in Finance (No. 2) Act 2017 - Changes to EIS, SEIS and VCT investment schemes in FA 2018 - The introduction of LBTT in Scotland and LTT in Wales - Stamp duty changes proposed for FA 2020 - Enhanced material on the taxation of goodwill and loan relationships on a reorganisation Cases updated since the last edition include: - Gallaher Ltd v Revenue and Customs Commissioners [2019] UKFTT 207 (TC) (on application of s171 TCGA 1992) - Hancock [2019] 1 WLR 3409 (Supreme Court decision) - Trigg [2018] EWCA Civ 17 (Court of Appeal decision)




Tiley’s Revenue Law


Book Description

This is the ninth edition of John Tiley's major text on revenue law, covering the UK tax system, income tax, capital gains tax and inheritance tax, as well as incorporating sections dealing with corporation tax, international and European tax, savings and charities. This new edition is fully revised and updated with the latest case law, statutory and other developments, including Finance Act 2019. The book is designed for law students taking the subject in the final year of their law degree, or for more advanced courses, and is intended to be of interest to all who enjoy tax law. Its purpose is not only to provide an account of the rules but also to include citation of the relevant literature from legal periodicals and some discussion of, or reference to, the background material in terms of policy, history or other countries' tax systems. Copy the URL below to read a 2021 supplement highlighting new developments since the book's publication in 2019: https://www.bloomsbury.com/media/2v1ej5vw/tileys-revenue-law-supplement-2021.pdf




Tolleys Corporation Tax 2007 2008


Book Description

In alphabetical order, from accounting periods to venture capital trusts, this text brings together the legislation, case law and ancillary material needed to deal with all aspects of corporation tax compliance, planning and agreeing liabilities.




International Taxation of Manufacturing and Distribution


Book Description

The most thorough treatment of its subject available, this book introduces and analyses the international tax issues relating to international manufacturing and distribution activities, extending from the tax regime in the country where the manufacturing activities are located, through to regional purchase and sales companies, to the taxation of local country sales companies. The analysis includes the domestic tax laws relating to manufacturing and distribution company profits as well as international tax issues relating to income flows and the payment of dividends. Among the topics and issues analysed in depth are the following: – foreign tax credits; – taxation in the digital economy; – tax incentives; – intellectual property; – group treasury companies; – mergers and acquisitions; – leasing; – derivatives; – controlled foreign corporation provisions; – VAT and customs tariffs; – free trade agreements and customs unions; – transfer pricing; – role of tax treaties; – hedging; – related accounting issues; – deferred tax assets and liabilities; – tax risk management; – supply chain management; – depreciation allowances; and – carry-forward tax losses. The book includes descriptions of 21 country tax systems and ten detailed case studies applying the analysis to specific examples. Detailed up-to-date attention is paid to the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and other measures against tax avoidance. As a full-scale commentary and analysis of international taxation issues for multinational manufacturing groups – including in-depth consideration of corporate structures, tax treaties, transfer pricing, and current developments – this book is without peer. It will prove of inestimable value to all accountants, lawyers, economists, financial managers, and government officials working in international trade environments.




Advanced Topics in Revenue Law


Book Description

The last several years have seen fundamental changes to the UK tax system. Nearly the entirety of the UK corporation tax and international tax rules have been rewritten by three new statutes – the Corporation Tax Acts 2009 and 2010 and the Taxation (International and Other Provisions) Act 2010. The UK has also implemented major new policies affecting the taxation of pensions, charities, savings vehicles, 'non-doms' and the foreign profits of UK companies. In addition, European Union law, and especially the case law of the Court of Justice of the European Union, has had an increasingly important impact on UK corporation tax and international tax law in particular. This new book on advanced topics in UK tax law is derived from material previously found in John Tiley's major text on Revenue Law that has been expanded and comprehensively updated to take account of these developments. The book deals with Corporation Tax, International and European Tax, Savings and Charities, in a manageable and portable volume for law students and practitioners. It complements the material on UK Income Tax, Capital Gains Tax, and Inheritance Tax found in Revenue Law, 7th edition. Unlike other tax law books, this text explains the new rules found in CTA 2009, CTA 2010 and TIOPA 2010 in light of its legislative predecessors. The book contains extensive references to the new legislation and also to the former enactments in ICTA 1988 and elsewhere. Those familiar with the old law but wanting to find their way round the new will find this work particularly valuable. The book is designed for law students taking advanced tax courses in the final year of their law degree course and for graduate students, but is intended to be of interest to all who enjoy tax law. Its purpose is not only to provide an account of the rules but to include citation of the relevant literature from legal periodicals and some discussion of or reference to the background material in terms of policy, history or other countries' tax systems.