Archive for 'International Taxation'

What Will Vince Cable Do Now For The Isle of Man?

What Will Vince Cable Do Now For The Isle of Man?

Just over a year ago I wrote about the visit to the Isle of Man undertaken by Vince Cable, then Liberal Democrat Shadow Chancellor who today was appointed Secretary of State for Business and Banking in the new Conservative – Liberal cabinet. Despite having been a stern critic of the island, calling it a tax [...]

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What Is the Difference Between Residence and Domicile?

What Is the Difference Between Residence and Domicile?

One thing that can be clearly seen amid all the arguments over the status of Lord Ashcroft is that neither the press nor the politicians really understand the difference between someone being resident in the UK or being domiciled in the UK. It is rather painful to listen to the claim and counterclaim of so [...]

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What Is Transfer Pricing?

What Is Transfer Pricing?

“Transfer pricing” is an increasingly important and contentious area of international tax law. This is because so much of modern world trade involves the transfer of goods, intangibles or services within multinational enterprises (MNEs) – groups of companies or related businesses based in 2 or more countries. Such international trade offers scope for an MNE [...]

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Vince Cable Visits Isle of Man Tax Haven

Vince Cable Visits Isle of Man Tax Haven

The Liberal Democrat Shadow Chancellor has been a stern critic of the Isle of Man, calling us a haven for tax dodgers. He also demanded that the Isle of Man be closed as a ‘tax haven’ and for banks receiving investment from the UK Government to shut offshore operations. Despite that he accepted an invitation [...]

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UK Praises Isle of Man Stance on Tax Standards

UK Praises Isle of Man Stance on Tax Standards

There are stunned expressions on the faces of Isle of Man politicians, civil servants and business leaders who have just read an official press statement from Stephen Timms, Financial Secretary to the UK Treasury, seen here behind his political master Gordon Brown. After months, indeed years of undisguised hostility, most blatantly with Chancellor Alistair Darling’s [...]

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Is the Isle of Man Really a Tax Haven?

Is the Isle of Man Really a Tax Haven?

I live in the Isle of Man. For those of you who don’t know this is a small island in the middle of the Irish Sea about midway between England, Scotland and Ireland (and a little further from Wales).   Although one of the British Isles we are an independent country – with the oldest [...]

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Withholding Tax Under Challenge

Withholding Tax Under Challenge

I recently received a question from the owner of a UK company questioning the imposition of Spanish withholding tax on payments his company received from a Spanish subsidiary. He thought that the EU Parent-Subsidiary Directive exempted the tax. In fact it would do for dividends but not for royalty payments, which these payments were for [...]

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