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The Transfer Pricing Law Review - 4th edition - United Kingdom chapter Preface by Steve Edge and Dominic Robertson for the fourth edition of The Transfer Pricing Law Review. UK chapter by Steve Edge, Dominic Robertson and Tom Gilliver. As we have said in earlier editions of the Review, transfer pricing rules will be high on...
What's (not) changing in pensions tax? The proportion of people in the UK aged 65 or over is projected to reach almost a quarter by 2037, and engagement with workplace pensions schemes increased by around a third following the introduction of automatic enrollment in 2012.  It may then...
Standards in tax: the influence of economics and politics on tax policy and tax preferences Steve Edge argues that we are, once again, in the midst of the debate as to whether the rules of economics or politics should determine tax policy — and what sorts of actual or perceived tax avoidance should be targeted by tax administrators. Over...
Sale and leaseback transactions: leveraging capital from real estate portfolios The COVID-19 pandemic has put a considerable strain on the cashflow of many businesses. With traditional debt markets hardening, sale and leaseback transactions may be an attractive alternative, enabling access to capital from valuable real estate while...
Climate Financial Risk Forum publishes guidance for firms on climate-related risks and opportunities On 29 June 2020 the Climate Financial Risk Forum published guidance to help FCA and PRA-regulated firms of all sizes understand the risks and opportunities that arise from the climate emergency and to support firms in integrating these risks and...
BLOG: Loosening up access to information The UK government has announced plans to introduce a “Financial Institution Notice” which would allow HMRC to request information from financial institutions without prior tribunal approval. The stated aim of this measure is to “bring the UK’s rules into...
Pensions Bulletin - July 2020 GMP equalisation; EU-US Privacy Shield; PPF COVID-19 levy; Equalisation close Barber window; High Court and RPI hard-wiring. Welcome to the July 2020 Pensions Bulletin from Slaughter and May. In this month's edition, we analyse HM Revenue &...
Tax residence post-MLI Under the MLI (meaning the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS developed by the OECD) residence tie-breakers have been removed from some of the UK's tax treaties in favour of competent authority...
Insurance Newsletter - July 2020 This newsletter highlights selected legal and regulatory developments in insurance. In this newsletter: The future of insurance regulation post-Brexit Green recovery and the insurance sector The impact of COVID-19 on insurer solvency
Back to the future When I first qualified into tax, UK-UK transfer pricing was not a thing.  A UK company could lend money to a fellow UK group company without being required to impute interest on the loan.  A UK parent could guarantee the loan of its UK...