CFC

Sarah Ling

Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.

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.

Tim Sarson

Tim Sarson (KPMG) provides your monthly update on international tax.

Paul Davison

The Commission neatly shifts its position on the UK’s CFC rules, writes Paul Davison (Freshfields Bruckhaus Deringer).

Dan Neidle

Rob Sharpe

The European Commission concludes that part of UK’s CFC tax regime gave unlawful state aid to certain multinational companies. Dan Neidle and Rob Sharpe (Clifford Chance) report.

James Taylor

James Taylor (EY) considers the application of the directive that requires minimum standards of anti-avoidance legislation across the EU.

David Harkness Dan Neidle Rob Sharpe

David Harkness, Dan Neidle and Rob Sharpe (Clifford Chance) consider the European Commission’s new state aid investigation which takes aim at the UK’s CFC regime.

Chris Morgan

Chris Morgan (KPMG) reviews recent global tax developments

The paradox at HMRC, by James Brockhurst TEP (Lee Bolton Monier-Williams)

Chris Morgan

Chris Morgan reviews recent developments in the international arena, including: the cross-border group relief infringement proceedings which the EC has brought against the UK; the amendment to the Parent-Subsidiary Directive; the 2014 Budget in India; corporate tax changes in Japan; and updates from Poland and Sweden on proposed CFC rules and corporate tax reform respectively

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