Tax Talks

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Philip Gilliland

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Philip Gilliland is an associate in the Tax Department.

Prior to joining Proskauer, Philip trained in the London office of a major international law firm where he worked on restructuring and insolvency, corporate M&A and tax matters. During his training contract he undertook a secondment at Unilever.

Philip earned his B.A. from St Catharine’s College, University of Cambridge.

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HMRC Announces Welcome Changes to the QAHC Regime

By Stephen Pevsner and Philip Gilliland on Posted in Corporate tax, In the news, UK Tax
On 20 July 2022, the UK government published draft legislation for the Finance Bill 2022-2023. Of particular interest are amendments to be made to the qualifying asset holding company (QAHC) regime that was introduced from 1 April this year. The regime is part of the UK government’s attempt to increase the attractiveness of the UK … Continue Reading

COVID-19: OECD updates its guidance on residence and permanent establishments

By Stephen Pevsner and Philip Gilliland on Posted in Coronavirus, Corporate tax, In the news, UK Tax
Background From the beginning of the UK’s first lockdown in March of last year we have reported on the impact of the pandemic on individual and corporate tax residence and permanent establishment risk. In April 2020 the OECD published guidance on the impact of COVID-19 on double tax treaties (DTTs), including in relation to tax … Continue Reading

COVID-19: UK Chancellor announces significant extension of support packages

By Robert E. Gaut and Philip Gilliland on Posted in Coronavirus, In the news, UK Tax
The UK Chancellor has today announced that the Coronavirus Job Retention Scheme (the furlough scheme) and the Self-Employment Income Support Scheme (SEISS) will be extended against “a worsening economic backdrop”. Earlier this week we reported on the UK Prime Minister’s reintroduction of the furlough scheme until 2 December 2020 (the scheduled end date of the … Continue Reading

COVID-19: Extension of economic support ahead of national lockdown

By Robert E. Gaut and Philip Gilliland on Posted in Coronavirus, In the news, UK Tax
Ahead of England’s return to national lockdown this Thursday, the UK Prime Minister has announced the extension of support packages for both employed workers and for the self-employed. As reported by us previously (https://www.proskauertaxtalks.com/2020/09/uk-chancellor-announces-winter-economy-plan/) the Coronavirus Job Retention Scheme (the furlough scheme) was due to end and its replacement, the Job Support Scheme, was to … Continue Reading

COVID-19: Further extension to the UK’s Job Support Scheme

By Robert E. Gaut and Philip Gilliland on Posted in Coronavirus, In the news, UK Tax
As coronavirus infection rates rise and restrictions tighten across the UK, the UK Chancellor has extended the Job Support Scheme (again). Last week we reported on the extension of the Scheme to businesses legally required to close under tier 3 of the alert system (https://www.proskauertaxtalks.com/2020/10/covid-19-extension-of-the-uks-job-support-scheme/). Yesterday (22 October) the UK Chancellor announced the following updates: … Continue Reading

COVID-19: Extension of the UK’s Job Support Scheme

By Robert E. Gaut and Philip Gilliland on Posted in Coronavirus, In the news, UK Tax
As lockdowns loom across the land with the introduction of a three-tier system of restrictions based on local COVID-19 alert levels, at the highest alert level (tier 3) certain businesses will be forced to close, including pubs and bars (unless they serve substantial meals). To support businesses that are legally required to close as a … Continue Reading

Cayman Islands removed from the EU blacklist of non-cooperative jurisdictions for tax purposes

By Robert E. Gaut and Philip Gilliland on Posted in In the news
The European Council has announced its decision to remove the Cayman Islands from the EU list of non-cooperative jurisdictions for tax purposes. In February we reported on Cayman’s inclusion on the list and our expectation that Cayman would make every effort to ensure its removal from the list in cooperation with the EU (https://www.proskauertaxtalks.com/2020/02/cayman-islands-added-to-the-eu-blacklist-of-non-cooperative-jurisdictions-for-tax-purposes/). The … Continue Reading

UK Chancellor announces Winter Economy Plan

By Robert E. Gaut and Philip Gilliland on Posted in Coronavirus, In the news, UK Tax
As the UK braces itself for a second wave of COVID-19 the UK Chancellor has announced the Treasury’s Winter Economy Plan with the aim of protecting jobs and supporting businesses over the coming months. Despite the measures introduced in the Chancellor’s Summer Statement (reported by us https://www.proskauer.com/blog/chancellors-summer-statement-focuses-on-hospitality-sector), the UK’s economic recovery “is fragile” amidst the … Continue Reading

HMRC updates its guidance on the VAT treatment of early termination fees and compensation payments

By Robert E. Gaut and Philip Gilliland on Posted in In the news, UK Tax
Following the European Court of Justice’s (ECJ) rulings in Meo and Vodafone Portugal, HMRC has recently updated its VAT manual and published a brief (https://www.gov.uk/government/publications/revenue-and-customs-brief-12-2020-vat-early-termination-fees-and-compensation-payments/) stating that payments arising out of early contract termination will now be treated as consideration for a taxable supply therefore subject to VAT. This marks a significant change from HMRC’s … Continue Reading

Chancellor’s Summer Statement focuses on hospitality sector

By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, In the news, UK Tax
As the UK’s lockdown is relaxed and unemployment figures are expected to continue to rise, the UK Chancellor gave his summer statement announcing measures to stimulate the economy as it recovers from the effects of coronavirus with a clear emphasis on encouraging people to spend money, particularly in the hospitality sector, to try to protect … Continue Reading

COVID-19: Taxation of coronavirus support payments

By Philip Gilliland and Robert E. Gaut on Posted in Coronavirus, In the news, UK Tax
The UK government has opened a consultation on draft legislation concerning the taxation of coronavirus business support payments. HMRC want views on the technical effectiveness of the proposed legislation in ensuring that grants covered by the legislation are subject to tax. Such grants include the much-reported Coronavirus Job Retention Scheme (“CJRS”) (as reported by us … Continue Reading

Advisers’ fees non-deductible where management decisions made by parent company

By Philip Gilliland and Stephen Pevsner on Posted in Corporate tax, UK Tax
The UK’s First-tier tax tribunal (FTT) has just released an interesting decision considering whether or not expenses incurred by a parent company on advisers’ fees that related to a proposed disposal by a group subsidiary and were charged on to its subsidiary were deductible as expenses of management of the subsidiary under section 1219 of … Continue Reading

IR35 extension to private sector – Finance Bill 2020 amendment on territorial scope

By Philip Gilliland and Stephen Pevsner on Posted in Corporate tax, In the news, UK Tax
There has been much discussion over the past year or so about the UK government’s proposal to make changes to the application of the off-payroll working (or IR35) tax rules to private sector end clients so as to shift certain employment status assessment and, depending on the circumstances, employment tax payment obligations from the worker’s … Continue Reading

COVID-19: DAC 6 reporting delayed

By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, Corporate tax, UK Tax
In light of COVID-19, and in response to requests from European trade associations, the European Commission has published its proposal to amend Directive 2011/16/EU which deals with various strands of administrative co-operation in the field of taxation. Significantly, the proposal includes an extension to the time limit for reporting information under the new rules on … Continue Reading

COVID-19: interim measures on stamp duty announced by HMRC

By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, In the news, UK Tax
In response to the COVID-19 crisis HMRC has updated its guidance on the process for getting documents stamped and paying the stamp duty, including that: Stock transfer forms should not be posted to the Stamp Office. Instead an electronic copy (which can be a scanned PDF) should be emailed to HMRC at stampdutymailbox@hmrc.gov.uk. The form … Continue Reading

COVID-19: HMRC Announces its Approach to Company Residence

By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, In the news, UK Tax
There has been considerable discussion about the effect that the travel restrictions resulting from the COVID-19 pandemic might have on the tax residence of companies, particularly where directors are stuck in a different jurisdiction and cannot attend board meetings as they would in normal circumstances. On 7 April, HMRC updated its published guidance to discuss … Continue Reading

COVID-19: UK Tax Residence for Companies and Individuals

By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, In the news, UK Tax
Introduction In these testing times the ramifications of COVID-19 continue to be felt in every area of personal and corporate life. With lockdowns announced around the world, including in the UK on 23 March 2020, travel has been severely curtailed and business practices are having to change accordingly. Below we discuss what this means for … Continue Reading

COVID-19: UK Chancellor announces measures to support the self-employed

By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, In the news, UK Tax
Earlier this evening (26 March 2020) the UK Chancellor announced the new Self-Employed Income Support Scheme to help the self-employed face the economic hardship wrought by the COVID-19 pandemic. Below are the key points: The scheme will provide direct cash grants of 80 per cent of individuals’ taxable profits (based on average monthly trading profit … Continue Reading

Coronavirus: UK Chancellor announces unprecedented measures to support the British economy

By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, In the news, UK Tax
Earlier this evening the UK Chancellor announced an economic intervention which is “unprecedented in the history of the British state” with measures to support the United Kingdom economy in the midst of COVID-19. Below are the key measures he announced for businesses: The government is setting up a Coronavirus Job Retention Scheme. The scheme will … Continue Reading

UK Budget 2020

By Katerina Heal and Philip Gilliland on Posted in Corporate tax, In the news, UK Budget
The UK Budget took place on 11 March. In its first post-Brexit Budget with substantial spending announcements, the Treasury wants to continue to ensure the UK remains an attractive and competitive place to invest and do business. We have summarized here the most notable tax changes that will be of interest to our corporate and … Continue Reading
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