Tag Archives: International tax

Manufactured Overseas Dividends

The Government has taken immediate steps to clarify the tax treatment of Manufactured Overseas Dividends (MOD) by publishing draft legislation to be incorporated within the 2012 Finance Bill. The legislation will take effect for MOD paid on or after the … Continue reading

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UK double taxation treaties and Delaware LLCs

The upper tax tribunal has released its decision in respect of HMRC v George Anson, a case which involved the interpretation of the UK/US double taxation agreement in respect of Delaware LLCs. By way of background it is helpful to … Continue reading

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