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International taxes
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International taxes
INTERNATIONAL-TAXES
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.
Tax and the City review for January 2022
Zoe Andrews
Mike Lane
The consultation on hedging risks for future share transactions and the FTT
decision in
Hargreaves
are some of the recent developments reviewed by
Mike Lane and Zoe Andrews (Slaughter and May).
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of
3
EDITOR'S PICK
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
1 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
2 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
3 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
4 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
5 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
6 /7
2024: that was the year that was
Jemma Dick
7 /7
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
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
NEWS
Read all
HMRC manual changes: 21 February 2025
HMRC launch e-invoicing consultation
NICs relief in special tax sites: postcode requirement introduced
Company size thresholds apply for off-payroll working rules
Paying voluntary NICs when abroad
CASES
Read all
A Taxpayer v HMRC
HMRC v Royal Bank of Canada
R (oao) Anglia Ruskin Students’ Union v HMRC
B Joseph v HMRC
Lloyds Asset Leasing Ltd v HMRC
IN BRIEF
Read all
Salaried members update
Themes in UK corporate tax disputes for 2025 (and beyond)
JVs and the top-up taxes: does HMRC’s draft guidance bring clarity?
Reflections on the Budget fallout – three months on
BlueCrest: the CA ruling on Condition B
MOST READ
Read all
Salaried members: HMRC reverses position on the TAAR and Condition C
Lloyds Asset Leasing Ltd v HMRC
Salaried members update
US ‘rejects very nature’ of UN tax talks
Mersey Docks: you’re my wonderwall