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Unfixed establishments: Barclays Services Corporation, fixed establishments, and VAT grouping

The Upper Tribunal (Tax and Chancery Chamber) (UT) has dismissed Barclays' appeal against the decision of the First-tier Tribunal (Tax Chamber) (FTT) upholding HMRC's refusal to allow a US company, Barclays Services Corporation (BSC), a member of Barclays' corporate group, to join Barclay's UK value added tax (VAT) group. The main reason for refusing the application was that the US company's registered branch in the UK was not a 'fixed establishment'.

The UK's carried interest tax regime

Since 6 April 2026, the UK has had a new regime under which all carried interest is taxed as trading income, regardless of the underlying nature of the return. As it is trading income, the starting position is that it is taxed at rates of up to 47% (45% income tax plus 2% national insurance contributions). However, provided the carried interest is "qualifying", a bespoke effective rate of around 34.1% applies.

Travers Smith advises on regulatory aspects of $35 billion capital solution for Broadcom AI XPV Platform

Travers Smith has advised on UK and EU financial regulatory aspects of an initial $35 billion capital solution as part of Broadcom's new AI XPV Platform, led by Apollo-managed funds and affiliates in partnership with Blackstone and leading global banks. The transaction represents the largest private financing ever executed and is designed to enable over 20GW in compute capacity for leading frontier AI labs through 2028.

ESG Circular - Issue 4 - Navigating Transition in a Changing World: Energy Security, Defence and Digital Innovation - June 2026

Geopolitical pressures, technological disruption and shifting energy markets are reshaping what it means to transition to a more sustainable economy. This edition examines how three sectors, energy, defence and digital, are navigating the transition and reviews the regulatory and financial framework that will determine whether the transition succeeds.

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