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International review for June 2022
Tim Sarson
Delay and a lack of political consensus on BEPS feature in this month’s review
by Tim Sarson (KPMG).
Tax and the City review for October 2021
Zoe Andrews
Mike Lane
The impact of the ruling in
Almacantar
, the latest on the economic crime levy and state aid issues are among the developments covered in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
State aid ruling on the UK’s CFC regime: an update on recovery
Paul Davison
Sam Withnall
Paul Davison and Sam Withnall (Freshfields Bruckhaus Deringer) report on the progress of the state aid recovery following the Commission’s final decision in its investigation last year.
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).
How to choose your holding company location
Charles Osborne
Sara Luder
Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.
UK SMEs expanding overseas through a local subsidiary
Adam Kefford
Daniel Sladen
What are the key tax issues for a UK SME establishing an overseas subsidiary? Adam Kefford and Daniel Sladen (PKF-Francis Clark) report.
The CFC group finance exemption: EC’s final decision
Francisco Alvarez Silva
Paul Farmer
Paul Farmer and Francisco Alvarez (Joseph Hage Aaronson) analyse the European Commission’s findings and the next steps to be taken.
EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
HMRC manual changes: 22 November 2024
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
Autumn Budget 2024: IHT winners and losers
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
Apprenticeship Levy and Employment Allowance: new employer guidelines