Alex Rigby
Alex Rigby represents a broad range of clients on U.K. and international tax matters. His practice includes representing clients on high-value tax controversy matters, including enquires by the U.K. revenue authorities, transfer pricing disputes and competent authority work such as APAs and MAPs. He also advises on a range of transactional tax matters, including public and private mergers and acquisitions, joint ventures, equity and debt issuances, demergers and restructurings, generally with an international component.
In recognition of his work on contentious matters, Mr. Rigby was named a Rising Star in Tax Controversy in ITR World Tax 2025 edition.
Mr. Rigby contributes to a number of Skadden’s pro bono projects, and has advised various individuals on their appeals against benefit decisions by the Department for Work and Pensions.
Practice Area
Panel
- Contributing Author
Qualified Year
- 2019
Qualifications
- B.A. (Hon) (2015)
- G.D.L. (2016)
- Legal Practice Course (2017)
Education
- University of Oxford (2015)
- BPP Law School (2016)
- BPP Law School (2017)
2 Contributions by Alex Rigby
PRACTICE NOTES
UK bank cross-border lending: withholding tax, treaty relief and processes, loan relationship taxation, stamp and VAT, FATCA, bank levies, financial transaction taxes
A UK tax resident bank should weigh the following tax matters when extending credit to an overseas borrower:
local withholding taxes, including:
the lender’s entitlement to double tax treaty (DTT) relief; and
the procedure required to access DTT relief
UK tax treatment of the loan
stamp, transfer, registration and comparable taxes
value added tax (VAT)
the US Foreign Account Tax Compliance Act (FATCA) and analogous regimes worldwide
bank levies
financial transaction taxes
Local withholding tax and a lender’s ability to claim double tax treaty relief
Local withholding tax
A principal tax point for a UK lender financing a non-UK borrower is whether any overseas withholding will cut the interest actually received and, if so, whether that charge can be reduced or removed through local exemptions or DTT relief. Provided the loan has not been arranged so the interest arises from a UK source, UK withholding tax should not come into play; and even if it does, it ought to have little practical impact given the lender’s UK tax residence and...
Tax
PRACTICE NOTES
UK corporate borrowing from overseas lenders: withholding tax (DTT/DTTP, QPP), deductibility (CIR, hybrids, transfer pricing), stamp/SDRT, VAT, FATCA, bank levies, Pillar Two, and forthcoming FA 2026 changes
FORTHCOMING CHANGE relating to UK transfer pricing legislation:
Finance Act 2026 (FA 2026) introduces a suite of revisions to the UK’s transfer pricing regime. Effective for accounting periods commencing on or after 1 January 2026, once enacted, the rules will, among other reforms, disapply UK-to-UK transfer pricing (with limited carve-outs to block tax arbitrage), revise the participation condition, and implement a range of updates to the financial transactions provisions so that UK requirements are closely aligned with the OECD Transfer Pricing Guidelines. In parallel, the government also confirmed at Budget 2025 that it will move ahead with an obligation for in-scope multinationals to submit annual information on cross-border related party dealings for accounting periods beginning on or after 1 January 2027—the detailed regulations for the new ‘International Controlled Transactions Schedule’ (ICTS) are anticipated in spring 2026 in due course. For further detail and background, see Practice Notes: Transfer pricing—the UK legislation and Tax—Finance Act 2026 tracker—progress through Parliament [Archived] and News Analyses: Finance Bill 2026—reform of UK law in relation to transfer pricing, permanent establishment and diverted profits tax and Budget 2025—Tax analysis—International...
Tax
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