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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?
Creina Kane
Jenni Bullivant
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
Lily Teh
Will Smith
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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EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
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Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
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The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
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Lynnette Bober
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Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
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Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
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HMRC manual changes: 13 December 2024
Scottish and Welsh Budget announcements
Lineker case settled
Anglesey Freeport: special tax sites designated
New overlap relief calculator
CASES
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C Hoyle and others v HMRC
Other cases that caught our eye: 13 December 2024
Five key cases of 2024
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
IN BRIEF
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A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
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Stage One Creative Services Ltd v HMRC
Other cases that caught our eye: 13 December 2024
L v HMRC
A third route to exit: tax consequences of continuation fund transactions
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