IMPORTANT NOTE: This article was first published in the Tax Journal on 4 October 2013. Since then, the content has been substantially updated and revised and now forms part of our Free Briefing on How to Create Effective Intercompany Agreements for Transfer Pricing. This Briefing takes into account the 2017 edition of the OECD’s Transfer […]
This is one of the most common issues which comes up in the context of group reorganisations or intercompany agreements. Although it may have been intended to put in place a new arrangement by a particular date – often a year end – that date may now have passed. The question is: can the documents […]
Market value vs Book value: invalidity risks on intra-group transfers Group reorganisations often involve the transfer of assets from one company to another. The assets may be tangible or intangible assets, or they may be a debt receivable which is owed by another group company. One of the key issues from a UK company law […]
Paul Sutton, Partner at law firm LCN Legal, has presented a training session for accountants on corporate simplification (also known as ‘legal entity reduction‘). The session focussed on the drivers for corporate simplification projects, as well as key lessons learned from managing similar projects.
Using Quoted Eurobonds to Address UK Withholding Tax In general, UK withholding tax becomes payable at the rate of 20% when a UK tax resident company pays interest on a loan to an overseas lender. Ordinarily, the UK borrower will not be disadvantaged because it can still benefit from a potential tax deduction for the […]
New law firm LCN Legal is launched, with the objective to complete projects for clients quickly and efficiently as possible, giving them the legal support they need when they need it, and the knowledge that they are in good hands. The firm’s main focus areas are legal implementation of group reorganisations and corporate simplification projects, […]
Please enquire by using the form below.