The UK Double Tax Treaty Passport ("DTTP") scheme has recently been extended by HM Revenue & Customs ("HMRC") to allow both non-corporate borrowers and lenders to enjoy the benefits of the scheme.

Inbound investment structures seeking to acquire a German or UK corporation should take into account the potential taxation of both the local entity and the shareholder.

On 4 December, George Osborne in his Autumn Statement, announced a new UK withholding tax exemption for interest payments on UK private placements.

In September 2011, the European Commission initially proposed that a financial transaction tax ("FTT") be implemented by all 27 EU Member States.

Beginning on 1 April 2013, the UK Government will reduce the rate of corporation tax payable in the UK on profits arising from patents and some other forms of intellectual property ("IP").

The Basel III rules which have now been finalised by the Basel Committee on Banking Supervision will have a significant impact on the amount of capital required to be held by banks and the nature of such capital.

On 1 September 2010, the new Double Taxation Treaty Passport ("DTTP") scheme became operative. According to Her Majesty’s Revenue & Customs ("HMRC") the new scheme will result in expedited treaty clearances and will provide a simpler and more efficient method of paying interest to overseas lenders, which has been sought after by businesses as an alternative to the present certified claim procedure for some time.

On 9 December 2009, the UK Government announced the introduction of a new one-off 50% Bank Payroll Tax (BPT) that will be payable by a bank on the amount of a bonus to which a banking employee is entitled.

HM Revenue & Customs has announced the abolition of the 1.5% Stamp Duty Reserve Tax (SDRT) on the entry of UK shares and some types of debt securities into certain clearing systems.