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Pillar two
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Pillar two
PILLAR-TWO
International review for January 2025
Tim Sarson
Tim Sarson (KPMG) reviews the latest developments and looks ahead at what
to expect in 2025.
The Trump effect: US foreign tax policy
Tanja Velling
Among the executive orders signed by President Trump is a firm rebuff of the OECD’s two-pillar solution, writes Tanja Velling (Slaughter and May).
Pillar Two one year on: what have we seen and where are we going?
Jisun Choi
Kara Heggs
Jisun Choi and Kara Heggs (Skadden, Arps, Slate, Meagher & Flom) take stock of some of the practical issues arising from Pillar Two.
Pillar Two and funds: there is no panacea
Andrew Yeomans
Alistair Godwin
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
Alistair Nichol
Lavina Hassasing
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).
Go to page
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7
EDITOR'S PICK
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
1 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
2 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
3 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
4 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
5 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
6 /7
2024: that was the year that was
Jemma Dick
7 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
NEWS
Read all
HMRC manual changes: 21 February 2025
HMRC launch e-invoicing consultation
NICs relief in special tax sites: postcode requirement introduced
Company size thresholds apply for off-payroll working rules
Paying voluntary NICs when abroad
CASES
Read all
A Taxpayer v HMRC
HMRC v Royal Bank of Canada
R (oao) Anglia Ruskin Students’ Union v HMRC
B Joseph v HMRC
Lloyds Asset Leasing Ltd v HMRC
IN BRIEF
Read all
Salaried members update
Themes in UK corporate tax disputes for 2025 (and beyond)
JVs and the top-up taxes: does HMRC’s draft guidance bring clarity?
Reflections on the Budget fallout – three months on
BlueCrest: the CA ruling on Condition B
MOST READ
Read all
Salaried members: HMRC reverses position on the TAAR and Condition C
Lloyds Asset Leasing Ltd v HMRC
Salaried members update
US ‘rejects very nature’ of UN tax talks
Mersey Docks: you’re my wonderwall