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Double taxation
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Double taxation
DOUBLE-TAXATION
Tax and the City review for July 2023
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.
Pillar Two: compatibility of the UTPR with double tax treaties
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.
Burlington and treaty purpose tests
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.
Hoey: you’d better PAYE up
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.
Dicey Rule 3: the Court of Appeal’s decision in Skat v Solo
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.
International review for August 2021
Tim Sarson
Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).
International review for April 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
Finance Bill 2021: hybrid mismatch rules version 2.0
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?
International holding structures: are they structurally sound?
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.
The three Ps of pillar one
Mark Bevington
Mark Bevington (ADE Tax) discusses the policy, politics and practicalities of
the pillar one proposals.
Go to page
of
5
EDITOR'S PICK
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
1 /7
SDLT: gardens, grounds and grazing
Max Schofield
2 /7
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
3 /7
A capital blow for deducting management expenses
Kyle O'Sullivan
4 /7
VAT on private school fees: 10 takeaways
Etienne Wong
5 /7
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
6 /7
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
,
Gabrielle Van der Haegen
7 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
A capital blow for deducting management expenses
Kyle O'Sullivan
VAT on private school fees: 10 takeaways
Etienne Wong
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
NEWS
Read all
HMRC manual changes: 6 September 2024
Oil and gas tax changes in danger of affecting UK economic growth, says OEUK
Off-payroll working
HMRC’s position on remittances upon divorce
EU approves extension of EIS and VCT
CASES
Read all
HMRC v S&L Barnes Ltd
Bilfinger Salamis UK Ltd v HMRC
S Hackett and another v HMRC
HMRC v Labeikis and others
Other cases that caught our eye: 6 September 2024
IN BRIEF
Read all
R&D claim notification
The everyday economy
Cleaning up: tax on gifts
The end of BADR?
Lease extensions and the 3% surcharge
MOST READ
Read all
R&D claim notification
Bilfinger Salamis UK Ltd v HMRC
HMRC v Labeikis and others
Oil and gas tax changes in danger of affecting UK economic growth, says OEUK
Off-payroll working