Cross-border: Tax
This part of the topic index contains cross-border resources on tax. Please select the resource that you require by clicking on the relevant tab below.
14
resources
These resources are maintained, meaning that we monitor developments on a regular
basis and update them as soon as possible.
| 1 | Comitology procedure An outline of the EU's comitology procedure (formerly regulatory procedure with scrutiny). | Practice notes | Maintained |
| 2 | Controlled foreign companies and attribution of gains: tax This practice note discusses the UK's controlled foreign company regime for accounting periods beginning before 1 January 2013 and the UK's rules on attributing gains of non-UK resident companies to UK residents. | Practice notes | Maintained |
| 3 | Cross-border dividend payments: tax A discussion of the tax issues that may arise when a company in one country pays a dividend to a shareholder in another. | Practice notes | Maintained |
| 4 | Cross-border interest and royalties payments: tax A discussion of tax issues that may arise when interest and royalties are paid between the UK and other countries. | Practice notes | Maintained |
| 5 | Discrimination: tax and EU principles This practice note discusses the impact that EU legal principles prohibiting discrimination have on UK tax law. | Practice notes | Maintained |
| 6 | EU law and its interpretation in the UK An outline of the EU legislative process and its interpretation in the UK. | Practice notes | Maintained |
| 7 | Holding and exploiting intellectual property: tax issues 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. | Practice notes | Maintained |
| 8 | Ordinary legislative procedure This note outlines the EU's ordinary legislative procedure (formerly co-decision procedure) and its history. | Practice notes | Maintained |
| 9 | Seeking a reference to the ECJ 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. | Practice notes | Maintained |
| 10 | Statutory interpretation and the doctrine of precedent An outline of the English court system, the doctrine of precedent, and the rules of statutory interpretation. | Practice notes | Maintained |
| 11 | Subsidiary or permanent establishment: tax This practice note discusses the UK direct tax implications of carrying on a business through a subsidiary or permanent establishment. | Practice notes | Maintained |
| 12 | The European Union after the Treaty of Lisbon This Practice note examines the impact of the Treaty of Lisbon on the decision-making procedures and substantive policies of the European Union. | Practice notes | Maintained |
| 13 | Thin capitalisation and transfer pricing A discussion of the UK's thin capitalisation and transfer pricing rules in the context of cross-border transactions. | Practice notes | Maintained |
| 14 | Withholding tax This practice note is a summary of the UK withholding tax rules on payments of interest and certain other payments (such as annual payments, guarantee payments, patent royalties and other royalties). It considers when withholding arises (including when interest has a UK source and when it is "yearly interest" rather than "short interest"). It also considers exemptions, such as the Quoted eurobond exemption and exemption under double tax treaties, and outlines the effect of the EU savings tax directive. Further, it discusses documenting for withholding tax, including gross-up clauses, and accounting for tax withheld. | Practice notes | Maintained |