DOUBLE-TAXATION

Mike Lane

Zoe Andrews

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the Court of Appeal decisions in Royal Bank of Canada and Civic Environmental Systems and the consultation on transfer pricing, DPT and permanent establishment.

Bezhan Salehy

Sarah Ling

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

Kyle Rainsford

Kyle Rainsford (Norton Rose Fulbright) examines the first UK case about the interpretation of a purpose rule in a double tax treaty which extends the recent approach of Blackrock HoldCo 5 to the international fiscal arena.

Hugh Gunson

Guy Bud

Hugh Gunson and Guy Bud (Charles Russell Speechlys) examine the Court of Appeal’s decision which has potentially far-reaching consequences for the PAYE system.

Philip Baker KC

Dilpreet K. Dhanoa

The Court of Appeal has upheld SKAT’s claims. Philip Baker QC and Dilpreet K. Dhanoa (Field Court Tax Chambers) analyse whether, from a legal and international tax perspective, this was the correct decision.

Tim Sarson

Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).

Tim Sarson

Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).

Nick Evans

Claudine Fox

The UK hybrid rules impose double taxation as currently enacted, explain Nick Evans and Claudine Fox (Baker McKenzie). Changes will be made, but do they go far enough?

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.