PERMANENT-ESTABLISHMENT

Sandy Bhogal and Kitty Swanson (Mayer Brown) consider the final output of action 15 of the OECD’s BEPS project and how this will apply to the UK.

Kevin Offer

Kevin Offer (Gabelle) reviews the case of English Holdings Ltd v HMRC, where corporate losses were claimed against income.

Shiv Mahalingham

Shiv Mahalingham (Duff & Phelps) identifies key changes to international transfer pricing guidance, regulations and case law that have occurred in the past few months.

James Ross

The Finance Bill hybrid mismatch legislation significantly expands the scope of the December draft legislation. James Ross (McDermott Will & Emery) reviews the changes.

Alison Lobb

Alison Lobb (Deloitte) considers the permanent establishment threshold and the consequences for cross-border trading.

Stuart Pibworth Will Smith Leonard Ng Chris Brause

Will Smith, Leonard Ng, Chris Brause and Stuart Pibworth (Sidley Austin) review recent developments within the investment funds industry which faces numerous challenges in the form of UK and international tax initiatives, as well as ongoing regulatory change.

Francisco Alvarez Silva

Francisco Alvarez Silva (Milestone Tax) answers a query on whether employees of another organisation can be considered ‘other personnel’ of a non-resident.

Allan Cinnamon

Allan Cinnamon (Cintax the Word Ltd) provides your monthly update.

Allan Cinnamon

Allan Cinnamon reviews the latest tax treaty developments this month, including BEPS Action 6; amendments to the US Model Tax Treaty; diverted profits in Australia; PE profit allocations; a Swiss Supreme court decision on beneficial ownership of dividends; and treaty provisions relating to PEs, equipment leasing and hybrids.

Peter Halford

Peter Halford (PwC Legal) considers AG Kokott’s opinion in the ‘Austrian goodwill’ case, including its implications for the Commission’s appeals to the CJEU in the ‘Spanish goodwill’ cases.

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