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ATAD

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Tim Sarson

The OECD’s much-awaited Pillar Two administrative guidance is among the recent developments reviewed by Tim Sarson (KPMG).

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Ashley Greenbank

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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.

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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).

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Laura Hodgson

Laura Hodgson (Travers Smith) explains why the proposed new rules may require businesses to bolster the substance of their EU holding companies.

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Gregory Price

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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).

Jenni Bullivant, Creina Kane, Aaron Mehta

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.

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Will Smith

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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.

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Sophie Donnithorne-Tait

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Serena Lee

Sophie Donnithorne-Tait and Serena Lee (Akin Gump) examine the rules using examples to illustrate outcomes pre and post January 2019.

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Ashley Greenbank

Even without a Budget, 2019 has been a year of significant change to the taxation of corporates, writes Ashley Greenbank (Macfarlanes).

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Tim Sarson

Tim Sarson (KPMG) reviews some of the interesting developments that unfolded over the past year in the international tax arena.

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