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OECD
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
Andrew Solomon
Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.
European Commission v Ireland and others
ECJ sets aside General Court’s State Aid judgment.
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
Unbridgeable divides? Recent developments do not bode well for a successful outcome to the process of reforming the international tax architecture, writes Philip Baker KC OBE (Field Court Tax Chambers).
Hybrids and dual inclusion income: are we there yet?
Richard Milnes
Fehzaan Ismail
Richard Milnes and Fehzaan Ismail (EY) assess the concept of dual inclusion
income under the UK hybrid provisions following a prolonged period of
iterative change.
International review for June 2024
Tim Sarson
Your monthly review of latest developments, by Tim Sarson (KPMG).
International review for February 2024
Tim Sarson
Tim Sarson (KPMG) reports on recent developments that matter from around the globe, in a rare month of respite from BEPS 2.0.
Tax and the City review for February 2024
Mike Lane
Zoe Andrews
The Court of Appeal’s decision in
Dolphin Drilling
and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
International review for January 2024
Tim Sarson
Tim Sarson (KPMG) reports on a flurry of activity across the international tax world and looks ahead at what to expect in 2024.
International review for October 2023
Tim Sarson
The international tax world is still dominated by BEPS 2.0 developments,
reports Tim Sarson (KPMG). This article includes an update on the national
implementation of Pillar Two.
Multinational top-up tax: an overview
Tamar Ruiz
Matthew Mortimer
The multinational top-up tax regime appears to be endlessly complicated. Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine ten aspects of the regime, including a ten-step process to navigating the rules.
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EDITOR'S PICK
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
1 /7
Freebies
David Whiscombe
2 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
3 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
4 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
5 /7
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
NEWS
Read all
HMRC manual changes: 1 November 2024
Chancellor targets businesses with CGT and IHT reforms
Spotlight on LLPs and disguised remuneration arrangements
New HMRC guidance for taxpayers on rental income
Land transaction tax in Wales: relief for special tax sites
CASES
Read all
GCH Corporation Ltd and others v HMRC
Abbeyford Caravan Company (Scotland) Ltd v HMRC
S Lefort v HMRC
Other cases that caught our eye: 1 November 2024
R (oao Rettig Heating Group UK Ltd (in liquidation)) v HMRC
IN BRIEF
Read all
Autumn Budget 2024: a tax hike with familiar terrain
Autumn Budget 2024: tax on corporates
Autumn Budget 2024: private equity reforms - a mixed bag
Autumn Budget 2024: non-doms - the end of an era
Autumn Budget 2024: nothing too scary about CGT
MOST READ
Read all
‘Arrangements’ that disqualify new EMI option grants
Pillar Two and funds: there is no panacea
A tale from the frontline of SDLT
Government to consult on new corporate re-domiciliation regime
Consultation tracker