Michael McGowan, Andrew Thomson and Emma Hardwick (Sullivan & Cromwell) review Action 6 of the BEPS report.
HMRC is considering reforming the rules to counter abuse. A recent update suggests it has some further thinking to do, writes Graham Elliott (Withers)
Traditional treaty principles that allocate taxing rights between residence and source states, which have long formed the cornerstone of international tax consensus, are undergoing rapid re-evaluation, writes Jonathan Schwarz (Temple Tax Chambers)
Gary Barnett considers the impact of the recent tribunal decision concerning the VAT principle of abuse of law.
David Anderson and Judith Lesar examine the highs and lows of the Halifax principle in three recent decisions.
The recent Pendragon case in the Court of Appeal might have cast some much needed clarity on the scope of the EU principle of abuse of rights in the context of VAT, comments Chris Bates.