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Two weeks to 13 June 2019

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK

Offshore receipts in respect of intangible property
It's vital that taxpayers consider how these new rules impact their business, as the wording of the legislation is sufficiently broad to apply to non-tax motivated arrangements and to catch amounts arising under almost any licence except outright sales of intangible property.  See our specialists' summary of the rules, which takes into account the impact of the draft regulations and guidance that were published by HMRC on 24 May 2019 and which are now the subject to consultation until 19 July 2019. Read more.

UK CFC State aid case - webcast on latest developments
Join our tax and legal specialists on Wednesday 19 June from 3-4pm to discuss the latest developments in this case - including the appeal lodged by the UK - and what you should be doing to prepare for the recovery process that HMRC will be starting very soon. Register here.

HMRC issues fresh batch of letters requesting completion of a "Certificate of Tax Position" in respect of taxpayer's offshore income and gains
We are aware that HMRC has once again issued letters to some taxpayers requesting information in respect of offshore income and gains. The letters request that the taxpayer completes the enclosed 'Certificate of Tax Position' by a specified deadline. Read more.