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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
Matthew Mortimer
Tamar Ruiz
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.
HMRC’s evolving approach to tax compliance for the largest businesses
Nicole Newbury
HMRC’s large business director, Nicole Newbury, outlines the department’s approach, including priority areas of focus and how it is evolving to reflect wider changes in the economy and customers’ circumstances.
Nomad employees: examining HMRC’s new guidance
Martin Shah
Martin Shah (Simmons & Simmons) reviews HMRC’s latest guidance on whether employees of overseas entities working temporarily in the UK give rise to a UK permanent establishment.
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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: 13 September 2024
Budget Responsibility Bill enacted
ECJ overturns General Court's judgment in Apple State Aid case
Chancellor confirms business tax roadmap will be in Budget
Sunset date for EIS and VCT relief
CASES
Read all
Barclays Service Corporation and another v HMRC
Janet Bray Ltd v HMRC
Equity Advisory Ltd and another v HMRC
Other cases that caught our eye: 13 September 2024
HMRC v S&L Barnes Ltd
IN BRIEF
Read all
Self’s assessment: Business Tax Roadmap
Recognising ‘imported losses’ under the loan relationship rules
Suspended penalties
R&D claim notification
The everyday economy
MOST READ
Read all
HMRC manual changes: 13 September 2024
Budget Responsibility Bill enacted
Self’s assessment: Business Tax Roadmap
Suspended penalties
The last word on tax appeals