International Tax and Double Tax Treaties

Temple Tax has some of the highest-regarded international tax experts at the bar.  The leading commentary on the application of double tax treaties, Schwarz on Tax Treaties, is authored from within Chambers and members are recommended by both the legal 500 and Chambers’ Guide.  In addition to UK courts and tribunals, members represent clients in mutual agreement procedures and international arbitration.  Temple Tax has members qualified to practice in New York, Canada, South Africa and the Republic of Ireland.  Below is a selection of matters on which members have recently advised:

• Double tax relief and the application of double tax treaties, in particular the source of cross-border income and capital gains, and the characterisation of foreign entities.
• UK Transfer pricing provisions.
• Permanent establishments and the Diverted Profits Tax.
• The non-residents CGT charge on UK property/property-rich companies.
• Internationally mobile individuals (in particular sports persons and entertainers), cross-border employee share compensation and pensions.
• EU law, in particular cross-border financial and commercial transactions including technology licencing, and corporate cross-border mergers, demergers, acquisitions and joint ventures.
• Shipping and tonnage tax.   
• Controlled Foreign Companies.
• Offshore funds and other cross-border investment funds.
• International exchange of information and cross-border tax enforcement