Tax

Briefings in English - 2008

The UK and France have signed a new double taxation treaty (DTT). It is hoped that, unlike the treaty signed in 2004, this DTT will shortly replace the 1968 UK-France treaty. This briefing examines how multiple taxation can arise and the role of DTTs in mitigating this difficulty; discusses the key ‘mainstream’ provisions of the new UK-France DTT compared with those in the 1968 treaty; and considers the new DTT’s more novel features. (July 2008)

Scope of the alternative finance arrangements provisions. Part 2: Rules for deposits and bonds. In the second of two articles, Colin Hargreaves, Paul Davison and Sarah Perfect, Freshfields Bruckhaus Deringer, continue to examine how Sharia financing rules may apply more widely than expected. The Tax Journal, Monday, 4 February 2008. (February 2008)

This guide outlines the principal changes, highlights how different categories of taxpayer could be affected and suggests action that may be taken in anticipation of the changes. It also includes some comments about loan note alternatives. The Appendices go into more detail on some of the issues and includes some numerical examples. (February 2008)

Scope of the alternative finance arrangements provisions. Part 1: Purchase/resale and shared ownership. Colin Hargreaves, Paul Davison and Sarah Perfect of Freshfields Bruckhaus Deringer examine whether special rules for Sharia financing arrangements can apply more widely than might be expected. The Tax Journal, Monday, 28 January 2008. (January 2008)

This client guide is an update of our August 2006 guide and aims to provide an introduction to the regime as amended by the FA 2007, while noting some of the more difficult issues currently raised by the regime. It also covers the current proposals for changes to the reference number system. This guide does not consider the VAT, SDLT or NICs regimes. (January 2008)

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