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ATAD


International review for February 2023 premium
Card image Tim Sarson
The OECD’s much-awaited Pillar Two administrative guidance is among the recent developments reviewed by Tim Sarson (KPMG).
21 February 2023
ATAD 3: what are the consequences of being a shell? starpremium
Card image Ashley Greenbank
Card image Sarah Ling
Ashley Greenbank and Sarah Ling (Macfarlanes) examine what the tax consequences of ATAD 3 will be in practice for four structures involving EU shell companies.
18 May 2022
International review for March 2022 premium
Card image Tim Sarson
OECD commentary on the pillar two model rules and the responses to the pillar one public consultations are among the recent developments examined by Tim Sarson (KPMG). 
22 March 2022
‘Am I a shell?’ The new question facing EU entities starpremium
Card image Laura Hodgson
Laura Hodgson (Travers Smith) explains why the proposed new rules may require businesses to bolster the substance of their EU holding companies.
8 February 2022
The war on holding companies and the return of withholding taxes premium
Card image Gregory Price
Card image Sarah Ling
BEPS 2.0 and ATAD 3 represent the latest challenge to the tax status of holding companies, renewing focus on issues of substance and withholding taxes, write Gregory Price and Sarah Ling (Macfarlanes).
29 September 2021
International holding structures: are they structurally sound? premium
Card image Aaron Mehta Creina Kane Jenni Bullivant
Jenni Bullivant, Creina Kane and Aaron Mehta (PwC) reflect on the host of international tax issues and complexities associated with international holding structures as a consequence of the continually changing external landscape. 
26 March 2021
Taxation of credit funds: from one crisis to another premium
Card image Will Smith
Card image Lily Teh
Will Smith and Lily Teh (White & Case) consider some of the major trends and tax issues relevant to the establishment and operation of credit funds. 
2 July 2020
Have changes to the UK’s CFC rules created thousands of ‘surprise’ CFCs? premium
Card image Sophie Donnithorne-Tait
Card image Serena Lee
Sophie Donnithorne-Tait and Serena Lee (Akin Gump) examine the rules using examples to illustrate outcomes pre and post January 2019.
15 January 2020
2019 review: taxing times for corporates premium
Card image Ashley Greenbank
Even without a Budget, 2019 has been a year of significant change to the taxation of corporates, writes Ashley Greenbank (Macfarlanes).
10 December 2019
International review: looking back on 2019 premium
Card image Tim Sarson
Tim Sarson (KPMG) reviews some of the interesting developments that unfolded over the past year in the international tax arena.
27 November 2019
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