Unilateral relief meaning

Market studies CMA publishes provisional findings in cloud services market investigation; recommends new digital markets investigation The CMA has issued provisional conclusions from its market investigation into the provision of public cloud infrastructure services in the UK. The authority made a market investigation reference in October 2023, following a market study of the sector. In that study, the CMA judged there were reasonable grounds to suspect that a feature, or a combination of features, in the market for the UK supply of public cloud infrastructure services may prevent, restrict, or distort competition. It has provisionally determined that high levels of overall concentration, together with barriers to entry and expansion, have conferred significant unilateral market power on Amazon Web Services (AWS) and Microsoft across the UK cloud services market. The CMA also provisionally considers this market power to be further reinforced by various commercial barriers, notably egress fees, as well as by technical barriers, including the practical complications involved in effectively operating multi-cloud services. In addition, the authority has provisionally...

In this issue: Residential property Property management Transferring property Corporate and structured property transactions Property development Environment, energy and buildings Easements, rights and covenants Property taxes Property in Wales Property in Scotland LexTalk®Property: a Lexis®Nexis community Additional property updates this week Daily and weekly news alerts Trackers Residential property Court of Appeal recasts meaning of ‘building’ in rights of first refusal In SGL 1 Ltd v FSV Freeholders Ltd [2026] EWCA Civ 267, the Court of Appeal (Civil Division) upheld the appeal by SGL1 Limited (the Appellant) against FSV Freeholders Limited (the Respondent). The dispute concerned the construction of ‘building’ for Part 1 of the Landlord and Tenant Act 1987 and the validity of section 5 notices served by the administrators of Fox Street Village Limited. The central question was whether Blocks A, B, C and E at Fox Street Village, Liverpool, comprised a single building or several buildings,...

Many UK-resident companies are expected to operate solely within the UK, with their entire customer base and supplier network located here, so that all profits and gains arise from UK activity undertaken domestically within national borders. Nevertheless, this is not universal; for a sizeable proportion of UK companies, overall profits also comprise non-UK amounts earned from activities outside the UK...

A unilateral credit against UK inheritance tax (IHT) can be claimed when property has been subjected to a tax comparable to IHT in a territory outside the UK. HMRC sets this out in the Inheritance Tax Manual at IHTM27185. Information for particular jurisdictions is available in the International Q&A guides—Private Client subtopic. When does unilateral relief apply? It chiefly operates for territories where double tax relief is not available. If the UK has a double tax treaty with the other territory, double tax relief for IHT applies instead. Both mechanisms aim to prevent the same asset being charged to inheritance or estate taxes in both jurisdictions. Double taxation can occur because: jurisdictions tax by reference to different factors (for example, the residence, domicile or nationality of the deceased or the heirs, or the location of assets). Some may apply more than one of these even where the basis aligns, definitions may vary (for instance, of movable and immovable property, or of asset location)...

International tax law International tax law primarily concerns states’ taxing rights. As with other areas of international law, the need to resolve these matters arises from jurisdictional conflict. Conflicts occur when more than one state claims the power to impose a similar charge on the same arrangement or transaction. There are two forms of double taxation: economic double taxation, which relates to continuity of the tax object (ie the same property being taxed), and juridical double taxation, which relates to continuity of the tax subject (ie the same person being taxed) and can be described as two or more taxes levied on the same property, on the same person, during the same period, for the same purpose Double taxation can be avoided or reduced under UK domestic law and that of other countries (see below Unilateral relief—income and capital gains), as well as through double tax treaties (DTTs). The Organisation for Economic Co-operation and Development (OECD) has developed a model DTT...

This Agreement is entered into on [ date ]. Parties [ Insert name of party ] [ of [ insert details ] OR a company incorporated in [ England and Wales ] under number [ insert registered number ], whose registered office is at [ insert address ] ] (the Discloser); and [ Insert name of party ] [ of [ insert details ] OR a company incorporated in [ England and Wales ] under number [ insert registered number ], whose registered office is at [ insert address ] ] (the Recipient). Each of the Discloser and the Recipient is a party and, collectively, the Discloser and the Recipient are the parties. Background The Discloser is [ insert details ] and the Recipient is [ insert details ]. The Discloser intends to provide Confidential Information to the Recipient for the Recipient to use solely for the Purpose. The Discloser seeks to manage such use and...