Tony Beare (Slaughter and May) examines the recent eagerly anticipated First-tier Tribunal decision of Next Brand Ltd v HMRC on dividend boosters.
As the OECD presses ahead with its agenda of expanding the PE concept, Richard Collier (PwC) asks how this will impact on existing structures and arrangements.
In the first of a new series, Allan Cinnamon provides a global review of tax treaty developments, including the UK’s DPT.
Chris Morgan (KPMG) provides a round-up of recent developments, including: recent OECD discussion drafts from the BEPS project; discussions on the introduction of a GAAR into the EU Parent-Subsidiary Directive; the CJEU judgment on TCGA 1992 s 13; and updates from Germany and Chile.
Our special report on the much awaited OECD report, with contributions from Paul Morton, Robert Langston, Alison Lobb and Heather Self
US giants can indeed claim not to be taxable on the full amount of UK sales, says Lydia Challen