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International taxes
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INTERNATIONAL-TAXES
International review for February 2025
Tim Sarson
This month’s review by Tim Sarson (KPMG) includes insight on the latest
developments from the US Administration and the European Community.
International review for January 2025
Tim Sarson
Tim Sarson (KPMG) reviews the latest developments and looks ahead at what
to expect in 2025.
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
Andrew Solomon
During Trump’s second presidential term, the spectre of tax cuts expanding the US federal budget deficit will fuel fierce debates between fiscally conservative and ‘pro-growth’ Republicans, write Donald L Korb and Andrew Solomon (Sullivan & Cromwell).
International review for July 2024
Tim Sarson
Pressure grows for a global wealth tax. This and other recent developments in
international tax are examined by Tim Sarson (KPMG).
HMRC v GE Financial Investments
CA holds that stapled entity not entitled to double tax relief.
International review for May 2024
Tim Sarson
Netherland’s new coalition government’s tax plans, the latest Canadian and Australian Budgets and several EU developments are included in this month’s review by Tim Sarson (KPMG).
Reform of the UK’s international tax laws: a step closer
Meenakshi Iyer
Joel Kara
Meenakshi Iyer and Joel Kara (BDO) review the outcome of the consultation on reforms to the UK’s transfer pricing, permanent establishments and diverted profits tax rules.
Skatteforvaltningen (SKAT) v Solo Capital Partners LLP (in special administration) and others
Revenue rule does not apply to Danish tax authority’s claims to recover funds.
International tax cooperation: the UN’s call for greater inclusivity and effectiveness
Sarah Blakelock
The UN is demanding a greater role in setting the global tax policy agenda,
but some countries have questioned whether this undermines the OECD/G20
Inclusive Framework discussions. Sarah Blakelock reports.
GE Financial, treaty residence, and the meaning of ‘business’
Kyle Rainsford
Kyle Rainsford (Travers Smith) examines the ramifications of the Upper Tribunal’s decision.
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EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 4 April 2025
Urgent action could be required on non-dom ‘double remittances’
HMRC set out Pillar Two territories
Additional information requirements for creative industry claims updated
Private schools VAT challenge
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
HMRC v Bolt Services UK Ltd
Other cases that caught our eye: 4 April 2025
HMRC v Innovative Bites Ltd and another
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC closing in on tax avoidance (again)
HMRC v Innovative Bites Ltd and another
Excluded property trusts and 6 April 2025
Chancellor hints on digital services tax
Country-by-country reporting goes public