CROSS-BORDER

Philippe Gamito and Irina Maslova (KPMG) review an advocate general’s opinion which adds significant complexity to VAT recovery by a branch supporting its foreign head office.

James Tryfonos

Eloise Walker

Eloise Walker and James Tryfonos (Pinsent Masons) provide a guide to the potential tax pitfalls in respect of interest rate swaps.

Martin Shah Hatice Ismail Gary Barnett

Hatice Ismail, Martin Shah and Gary Barnett (Simmons & Simmons) review the EC’s proposal for a directive to impose mandatory reporting obligations on intermediaries and taxpayers involved in certain cross-border tax planning arrangements.

Nigel Barker Jenny Tevlin Annis Lampard

Nigel Barker, Annis Lampard and Jenny Tevlin (Deloitte) examine what Schedule 36 powers mean in practice, and unwrap the latest trends in HMRC analytics.

Donald L. Korb

Andrew Solomon

Donald L Korb and Andrew Solomon (Sullivan & Cromwell) review the challenges facing the Trump administration’s efforts to enact a comprehensive overhaul of the US tax code.

Lee Squires

Fiona Bantock

Lee Squires and Fiona Bantock (Hogan Lovells) report the latest VAT developments that matter.

Simon Whitehead

Peter Stewart

Simon Whitehead and Peter Stewart (Joseph Hage Aaronson) review the recent decision in Six Continents, which considers what foreign profits should receive credit at the foreign nominal rate following an earlier ruling of the CJEU in the FII group litigation.

Robert Thomas

Ian Hyde

BEPS Action 14 sets out the principles for resolving international tax disputes in the future. The International Chamber of Commerce will be contributing to this debate at an OECD level. Ian Hyde (Pinsent Masons) and Robert Thomas (chair of the UK tax committee of the International Chamber of Commerce) share the findings of a recent ICC UK survey, which reveals strong support for introducing a mandatory binding arbitration and for greater taxpayer involvement in the arbitration process.

Simon Whitehead

Philippe Freund

The Court of Appeal has handed down its judgment in the Prudential case, in what is hoped to be one of the final steps of this long lasting action between taxpayers invested in cross border portfolio holdings and HMRC. Simon Whitehead and Philippe Freund (Joseph Hage Aaronson), who acted for the taxpayers, summarise the outcome of this judgment and explain why it has taken so long.

Lee Squires

Fiona Bantock

Lee Squires and Fiona Bantock (Hogan Lovells) look at recent developments, including: the decisions in Riskstop Consulting and Hedqvist; VAT on pension fund management costs; and the EC consultation on cross-border e-commerce.