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James Wilson

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James Wilson leads Baker McKenzie's global Tax Planning, Transactions and Tax Policy group. He has 18 years of experience in advising the world's largest multinational corporations on cross-border tax matters. James is a recommended lawyer for International Tax in Legal 500 USA, in particular for his expertise in advising clients in the consumer goods and retail sector. James is a member of the Firm's Consumer Goods and Retail Industry Group steering committee.

HMRC has published its response to the recent consultation on the operation of the UK hybrid-mismatch rules along with draft legislation to amend the rules in various respects. Although the consultation document identified discrete areas where HMRC were seeking views, HMRC also welcomed broader feedback on the current operation of legislation to the extent it was not operating proportionately or as intended. 

HMRC’s proposals only offer partial solutions to many of the issues identified by stakeholders. In particular, US multinational groups may continue to suffer material disallowances under the double deduction rules in some common (and benign) commercial structures. It is clear from our recent discussions with HMRC that they have endeavored strike a balance between fixing some of the issues with the current legislation while ensuring the rules cannot be manipulated. The remaining pitfalls within the legislation which continue to lead to economic double taxation are therefore deliberate policy choices that HMRC intends to stick by irrespective of the harmful consequences for some taxpayers.

Whether you are managing the immediate crisis, stabilizing operations or looking beyond to what a world after COVID-19 will look like, this series features key practical insights intended to strengthen your organization’s capacity to respond, recover and thrive. Subscribe: Apple Podcasts | Spotify | Google Podcasts Episode 1: The Reopening Playbook As some countries begin…

The adverse consequences of COVID-19 could be broad, including reduction of consumer demand, supply chain disruption, and an increase in risk aversion in financial markets (driven by an overall downturn in business and consumer confidence). Local subsidiaries of multinational enterprises (MNEs) in affected regions, even those that are operating “business…