HYBRIDS

James Ross

James Ross (McDermott Will & Emery) reviews recent developments to the hybrid mismatch rules and HMRC’s draft guidance.

Sandy Bhogal and Kitty Swanson (Mayer Brown) consider the final output of action 15 of the OECD’s BEPS project and how this will apply to the UK.

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EDITOR'S PICK

Lost the battle but winning the war? The Supreme Court’s decision in PGMOL

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Donald L. Korb , Andrew Solomon

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The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays

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Reform of the international tax architecture: the UN fails to reach consensus

Philip Baker KC

6 /7

SDLT: gardens, grounds and grazing

Max Schofield

7 /7

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

Reform of the international tax architecture: the UN fails to reach consensus

Philip Baker KC

SDLT: gardens, grounds and grazing

Max Schofield

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HYBRIDS

EDITOR'S PICK