A tax cloud hanging over Luxembourg real estate funds invested in France

The concept of partnership as defined in French tax law is currently changing. This is prompting fears with regards to the evolution of the taxation on capital gains on the disposal of shares in a partnership whose assets consist mainly of real estate.

'Overspent, not overtaxed' - the Emergency Budget

George Osborne delivered his first fiscal statement as Chancellor of the Exchequer in today's Emergency Budget. As with all emergencies, we saw the flashing blue lights of tax-raising headlines and triage to deal with the wreckage of the structural deficit in the British economy.

A Budget for Recovery?

The Budget 2010 was billed as "Securing the Recovery", but is perhaps better branded as a "Budget for First-Time Buyers".

Non-UK resident companies and liability to UK tax

It has been long-established law that the test for tax residence of a non-UK incorporated company is the place from which central management and control (CMC) is exercised. To answer this question requires a determination of by whom CMC is exercised.

Business rate supplements

The Business Rate Supplements Act 2009 provides levying authorities with a discretionary power to impose a business rate supplement (BRS) of up to two pence per pound of rateable value to fund certain projects that promote local economic development.

Business rates and tenants in administration

Where a landlord forfeits its lease, subject to any available relief or exemption, the landlord is liable to business rates in respect of the premises.

Looking to raise some cash? Against IP?

To the surprise of many, Morgan Stanley has just announced a new US$250 million intellectual property securitisation for Vertex Pharmaceuticals, a large US bio-tech company.

Changes to pensions schemes: potential pitfalls for high earners

Where a company is looking at making a material change to the way in which benefits under its pension scheme are provided after 22 April 2009 or proposing to introduce a new arrangement there could be adverse tax consequences for high earning individuals.

Non-resident companies and UK tax on chargeable gains

Non-UK resident companies are still outside the territorial scope of UK corporation tax on chargeable gains, provided that the company does not have a UK permanent establishment.

Government unveils new trade credit insurance scheme

A £5 billion initiative, unveiled as part of Wednesday's Budget, will enable companies which have had their trade credit insurance cover reduced by traditional providers to purchase 'top-up' credit insurance from the Government.

A Budget for real estate?

Today Chancellor Alistair Darling made his second, and one of the most eagerly awaited, Budget statements. Is this a Budget for real estate? The good news is limited.

IP or no IP? Is that the question?

With asset values on the whole diminishing, a number of funders are revisiting their corporate loan portfolios to examine their security packages, both in relation to valuation and enforceability. Are lenders as secure as they thought?

The Community Infrastructure Levy

Regeneration and development requires additional infrastructure to support it. The CIL is a new statutory planning tariff which will aim to ensure that a proportion of the cost of providing that infrastructure is obtained from landowners and developers.

Limited liability partnerships and UK real estate

The Limited Liability Partnerships Act 2000 created a new form of legal entity known as a LLP, which has unlimited legal capacity and can be used to carry on any form of lawful business including dealing with UK real estate development and investment.

When are overseas trust companies UK resident?

On 27 January 2009 HM Revenue & Customs published draft guidance on the application of the residence tests to overseas trust companies. This guidance is important and relevant to investors holding an interest (or units) in an offshore trust or unit trust.

Are you getting maximum bang for your IP buck?

Intangible assets, of which Intellectual Property (IP) is often the most significant, represent more than 50% of the value of most companies. But these assets are coming under increased scrutiny.

Backdated business rates - paying in instalments

On 9 March 2009 regulations will come into force allowing for backdated business rates to be paid in instalments where a rating list is altered with retrospective effect.

To buy or not to buy - when is the question

The headlines can make it feel as though hanging on for dear life is the only thing left to do in this economy. However, the same economic cycle that's brought us to this point can bring up some useful opportunities for those that spot them.

To buy or not to buy - when is the question

The headlines can make it feel as though hanging on for dear life is the only thing left to do in this economy. However, the same economic cycle that's brought us to this point can bring up some useful opportunities for those that spot them.

Something for nothing... and your dividends for free

Practical tips for action to take from Wragge & Co's Tax team: get something for nothing and your dividends for free.

Employees: to employ or not to employ? And should we all be making sacrifices now?

The headlines can make it feel as though hanging on for dear life is the only thing left to do in this economy: however, the same economic cycle that's brought us to this point can bring up some useful opportunities for those that spot them.

Research & Development tax credits - can you make or defend a claim?

The Research & Development (R&D) tax credits help companies to invest more in R&D either by reducing a company's tax bill or, for some loss-making small or medium sized companies (SMEs), by providing a cash sum.

Reclaiming tax from the Netherlands

UK pension funds which received dividends from Dutch companies on or before 31 December 2006 can now reclaim tax that was withheld on those dividends by the Netherlands tax authorities - claims will be possible for tax withheld as far back as 2003.

Making investments in UK real estate - a tax haven for non-UK residents?

There are many factors making the United Kingdom an attractive investment destination for a non-UK resident. One of these factors is favourable UK tax treatment and tax incentives given to investment in UK real estate.

When the going gets tough, the taxman gets tougher

Tips for action to take from Wragge & Co's Tax team to help businesses prepare for HMRC's tough tactics.

HMRC cashback

The headlines can make it feel as though hanging on for dear life is the only thing left to do in this economy. However, the same economic cycle that's brought us to this point can bring up some useful opportunities for those that spot them.

Planning for an upturn

The Wragge & Co Tax team tips for making the most of tax opportunities now and preparing for when the upturn comes.

Relocation, relocation

Will the last company to leave the UK please turn the lights out?  The news that United Business Media (UBM) is planning to follow Shire Pharmaceuticals out of the UK might be raising some questions in government at the moment.

VAT on electronic services - the rules are changing

The rules on charging VAT on electronic services are changing.

The Budget 2008

So was this the 'Green Budget' or the Budget of 'resilience' - Alistair Darling's version of 'prudence'? No doubt the media will be the judge.

Tax credits - deadline fast approaching

Following changes to the Finance Act 2006, all companies are required to finalise their Research & Development (R&D) tax credit claims by 31 March 2008, for the periods 1 April 2002 - 31 March 2006.