Joshua Stevens is an associate in Sullivan & Cromwell’s London office advising on general U.K. corporate tax matters, in particular the tax aspects of M&A, capital markets and banking transactions, as well as the application of European Union state aid rules in the tax sphere.
Articles de l'auteur
- Revue FI 3-2022 Fiscalités étrangères
Royaume-Uni - Pillar 2 - The government has published a summary of responses received to its consultation on implementing Pillar 2 in the UK and draft legislation for a domestic minimum top-up tax.
HMT/HMRC, OECD Pillar 2: Consultation on implementation, 11 January 2022
- Revue FI 2-2022 Fiscalités étrangères
Royaume-Uni - VAT grouping - The Upper Tribunal decided four preliminary issues in a case on HMRC's removal of five subsidiaries of HSBC from its VAT group on the grounds that they were not entitled to grouping and in any case HMRC could exercise its discretion to remove them in order to protect the revenue..
HSBC Electronic Data Processing (Guangdong) Ltd & Others v Commissioners for HM Revenue and Customs  UKUT 00041 (TCC), 15 févr. 2022
- Revue FI 1-2021 Fiscalités étrangères
Royaume-Uni - Disallowance of interest deductions - Transfer pricing - Tax advantage main purpose and apportionment - The First-tier Tribunal allowed a taxpayer's appeal against the disallowance of interest deductions, although accepting that the transaction would have been different if entered into with an independent third party and finding that it had a main purpose of obtaining a tax advantage: the transfer pricing rules did not apply and the interest deductions should not be attributed to the tax purpose.
BlackRock Holdco 5 LLC v Commissioners for HM Revenue & Customs  UKFTT 443 (TC), 3 November 2020