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ATAD
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International review for February 2023
Tim Sarson
The OECD’s much-awaited Pillar Two administrative guidance is among the recent developments reviewed by Tim Sarson (KPMG).
ATAD 3: what are the consequences of being a shell?
Ashley Greenbank
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.
International review for March 2022
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).
‘Am I a shell?’ The new question facing EU entities
Laura Hodgson
Laura Hodgson (Travers Smith) explains why the proposed new rules may
require businesses to bolster the substance of their EU holding companies.
The war on holding companies and the return of withholding taxes
Gregory Price
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).
International holding structures: are they structurally sound?
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.
Taxation of credit funds: from one crisis to another
Will Smith
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.
Have changes to the UK’s CFC rules created thousands of ‘surprise’ CFCs?
Sophie Donnithorne-Tait
Serena Lee
Sophie Donnithorne-Tait and Serena Lee (Akin Gump) examine the rules using examples to illustrate outcomes pre and post January 2019.
2019 review: taxing times for corporates
Ashley Greenbank
Even without a Budget, 2019 has been a year of significant change to the taxation of corporates, writes Ashley Greenbank (Macfarlanes).
International review: looking back on 2019
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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2
EDITOR'S PICK
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
1 /7
SDLT: gardens, grounds and grazing
Max Schofield
2 /7
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
3 /7
A capital blow for deducting management expenses
Kyle O'Sullivan
4 /7
VAT on private school fees: 10 takeaways
Etienne Wong
5 /7
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
6 /7
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
,
Gabrielle Van der Haegen
7 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
A capital blow for deducting management expenses
Kyle O'Sullivan
VAT on private school fees: 10 takeaways
Etienne Wong
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
NEWS
Read all
HMRC manual changes: 6 September 2024
Oil and gas tax changes in danger of affecting UK economic growth, says OEUK
Off-payroll working
HMRC’s position on remittances upon divorce
EU approves extension of EIS and VCT
CASES
Read all
HMRC v S&L Barnes Ltd
Bilfinger Salamis UK Ltd v HMRC
S Hackett and another v HMRC
HMRC v Labeikis and others
Other cases that caught our eye: 6 September 2024
IN BRIEF
Read all
R&D claim notification
The everyday economy
Cleaning up: tax on gifts
The end of BADR?
Lease extensions and the 3% surcharge
MOST READ
Read all
R&D claim notification
Bilfinger Salamis UK Ltd v HMRC
HMRC v Labeikis and others
Oil and gas tax changes in danger of affecting UK economic growth, says OEUK
Off-payroll working