STATE-AID

Tim Sarson

Tim Sarson (KPMG) assesses the latest developments that matter in the international tax arena.

Tim Sarson

Tim Sarson (KPMG) provides your monthly update on international tax.

Francisco Alvarez Silva

Paul Farmer

Paul Farmer and Francisco Alvarez (Joseph Hage Aaronson) analyse the European Commission’s findings and the next steps to be taken.

Zoe Andrews

Mike Lane

Hybrid capital instruments technical noteFA 2019 repealed and replaced the regulatory capital securities regime from 1 January 2019 with a new hybrid capital instrument (HCI) regime. An HCI is a loan relationship under which the debtor (but not the...

Tim Sarson

Tim Sarson (KPMG) provides your monthly update on international tax.

Paul Davison

The Commission neatly shifts its position on the UK’s CFC rules, writes Paul Davison (Freshfields Bruckhaus Deringer).

Dan Neidle

Rob Sharpe

The European Commission concludes that part of UK’s CFC tax regime gave unlawful state aid to certain multinational companies. Dan Neidle and Rob Sharpe (Clifford Chance) report.

Alejandro Dominguez Gary Barnett Pierre-Régis Dukmedjian

There are limits to claims of illegal state aid in tax cases.

Kelly Stricklin-Coutinho

The role of commercial purpose in arm’s length rules is reconsidered by the CJEU, and appears more generous to taxpayers, writes Kelly Stricklin-Coutinho (39 Essex Chambers).