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Overseas subsidiary
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OVERSEAS-SUBSIDIARY
The VAT review for May 2022
Bryn Reynolds
Gary Barnett
This month’s update by Bryn Reynolds and Gary Barnett (Simmons & Simmons) covers the CJEU ruling on fixed establishments.
A tale of two companies in two cities: the CJEU’s ruling on fixed establishment in Berlin Chemie
Karen Killington
Karen Killington (KPMG) considers the impact of a recent case where the CJEU held that a subsidiary was not a fixed establishment.
The FII group litigation: the end of the beginning or the beginning of the end?
Cristiana Bulbuc
Lee Ellis
The Supreme Court has handed down its third judgment in the long-running
FII GLO
case. Lee Ellis and Cristiana Bulbuc (Stewarts) consider how we got here and what this means for taxpayers with unresolved issues concerning overseas dividend taxation.
Transfer pricing guide to cash pooling arrangements
Daniel J. Pugh
John W. Lamszus
Selena Schneider
Selena Schneider, John W. Lamszus and Daniel J. Pugh (Crowe) provide a guide to this common treasury management tool used by multinationals to efficiently manage cash and reduce process and transaction costs.
UK SMEs expanding overseas through a local subsidiary
Adam Kefford
Daniel Sladen
What are the key tax issues for a UK SME establishing an overseas subsidiary? Adam Kefford and Daniel Sladen (PKF-Francis Clark) report.
EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
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
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
A tale from the frontline of SDLT
Pillar Two and funds: there is no panacea
One minute with... Paul Rosser
Government to consult on new corporate re-domiciliation regime