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IN BRIEF

Views on recent developments in tax.

There is now scope for some radical rethinking.
A recent tribunal decision serves as a reminder that the courts and tribunals are often wary of handling issues as preliminary matters.

There were huge sighs of relief in Brussels and beyond as the Council of EU finally overcame Hungary’s veto and approved the Commission’s Pillar Two Directive. In less visible developments, the Commission also published two completely new legislative proposals.

A flawed mechanism has been followed by a lack of communication.
The government agrees to a shorter ‘look-back’ period, but it will not be providing an online manual reporting system.
Payment for a restrictive undertaking: s 225 or s 401?
Offshore companies owning UK property are being asked to certify their tax position.
‘Sufficient’ is not the same as ‘substantial’.
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