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Pillar two
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Pillar two
PILLAR-TWO
Pillar Two and funds: there is no panacea
Alistair Godwin
Andrew Yeomans
Alistair Godwin and Andrew Yeomans (EY) review three areas of complexity
that present challenges to asset managers.
International review for October 2024
Tim Sarson
The proposed US regulations on Corporate Alternative Minimum Tax, an
important CJEU decision on state aid and the Irish Budget are among the
recent developments reviewed by Tim Sarson (KPMG).
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.
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).
International review for July 2024
Tim Sarson
Pressure grows for a global wealth tax. This and other recent developments in
international tax are examined by Tim Sarson (KPMG).
International review for June 2024
Tim Sarson
Your monthly review of latest developments, by Tim Sarson (KPMG).
Pillar Two: assessing the impact on the UK FTSE 100
Lavina Hassasing
Alistair Nichol
The expected impact of the new Pillar Two regime is starting to unfold as
the first UK groups have filed their calendar year-end consolidated accounts,
write Alistair Nichol and Lavina Hassasing (Evelyn Partners).
International review for May 2024
Tim Sarson
Netherland’s new coalition government’s tax plans, the latest Canadian and Australian Budgets and several EU developments are included in this month’s review by Tim Sarson (KPMG).
International review for April 2024
Tim Sarson
The Advocate General’s opinion on the CFC Finco exemption state aid case,
new US regulations and an update on Pillar Two are among the developments
in this month’s review by Tim Sarson (KPMG).
The impact of Pillar Two on tax risk apportionment for a corporate sale
Anne Powell
Anne Powell (Bryan Cave Leighton Paisner) considers how our historic experience of tax covenants steer us to resolve new Pillar Two risks.
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7
EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
HMRC manual changes: 13 December 2024
Scottish and Welsh Budget announcements
Lineker case settled
Anglesey Freeport: special tax sites designated
New overlap relief calculator
CASES
Read all
C Hoyle and others v HMRC
Other cases that caught our eye: 13 December 2024
Five key cases of 2024
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
IN BRIEF
Read all
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
Read all
Stage One Creative Services Ltd v HMRC
Other cases that caught our eye: 13 December 2024
L v HMRC
A third route to exit: tax consequences of continuation fund transactions
Consultation tracker