Paul Freeman

Dec 4, 2024 | kpmg.com | Paul Freeman

Our first article on this case focusses on when do arrangements have a main purpose of tax avoidance? When do arrangements have a main purpose of tax avoidance? KPMG in the UK›Insights›Tower One – An insight into ‘main purpose’ following the UT decisionUK tax law is littered with anti-avoidance rules which ask whether tax avoidance (or some similar concept) is “the main purpose, or one of the main purposes” of arrangements.

Nov 6, 2024 | kpmg.com | Paul Freeman |Sharon Baynham

What the Government’s roadmap tells us (or doesn’t) about the future of corporation taxWhat the Government’s roadmap tells us (or doesn’t) about the future of corporation taxPredictability, stability and certainty: these are the things which the Government’s newly published Corporate Tax Roadmap highlights as taxpayers’ priorities. Many businesses would warmly agree, but does the Roadmap deliver?

Jul 3, 2024 | kpmg.com | Paul Freeman |YouTube. Opens

The idea that a jurisdiction might wish to tax unrealised gains on assets and liabilities moving out of its tax net is a familiar one. Conceptually similar, but less prominent in practice, is the idea that a jurisdiction might also wish to deny relief for unrealised losses on assets and liabilities moving into its tax net. The UK rule which seeks to give effect to this latter goal in relation to assets or liabilities which are loan relationships is s327 Corporation Tax Act (CTA) 2009.

Jun 19, 2024 | kpmg.com | Paul Freeman |YouTube. Opens

Many factors influence the pricing of transactions in securities in international financial markets. One of these factors can be that not all market participants will be equally exposed to withholding tax (WHT) in respect of the securities concerned, and in some cases the likely existence of participants with differing exposures may be a straightforward explanation of why particular transactions may make economic sense for all involved.

Feb 1, 2024 | taxjournal.com | David Whiscombe |Paul Freeman |Andrew Goldstone |Jasmine Kaur

Home >Articles > Economic Crime and Corporate Transparency Act: new measures Economic Crime and Corporate Transparency Act: new measures 1 February 2024 Companies House has confirmed its intention to introduce the first set of measures under the Economic Crime and Corporate Transparency Act on 4 March 2024.