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Transfer pricing
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TRANSFER-PRICING
The UK’s new qualifying asset holding company regime
Elena Rowlands
Ian Zeider
Emily Clark
Emily Clark, Elena Rowlands and Ian Zeider (Travers Smith) give an overview of, and their verdict on, the QAHC legislation in the Finance Bill.
The UK asset holding company regime: a quacking idea!
James McCredie
James McCredie (Macfarlanes) reviews a hugely welcome new regime, but
explains there are still some ‘shoot in foot’ opportunities that it is to be hoped
the government and HMRC will resist.
International review for August 2021
Tim Sarson
Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).
Tax on establishing a business in Australia
Paula Tallon
Siobhan Sellick
Now that Australia and UK have signed their trade agreement, Paula Tallon and Siobhan Sellick (Prosperity Advisers Group) explain what Australian taxes UK companies will encounter when establishing a business presence there.
International review for July 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
International review for June 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
International review for May 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
IBOR transition: are you ready?
Mo Malhotra
Ben Moseley
Gemma Marshall
Ben Moseley, Mo Malhotra and Gemma Marshall (Deloitte) provide an
overview of some of the accounting, tax and transfer pricing implications, and
set out some actions that companies may wish to consider.
International tax and treasury issues in 2021
Andrew Cotterill
John Webb
Mairead Murphy
Interest deductibility, foreign exchange, withholding taxes... John Webb,
Andrew Cotterill and Mairead Murphy (PwC) review the key UK tax
considerations for financing transactions and global treasury functions.
Tax and the City review for February 2021
Zoe Andrews
Mike Lane
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
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10
EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
HMRC manual changes: 22 November 2024
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
Autumn Budget 2024: IHT winners and losers
Apprenticeship Levy and Employment Allowance: new employer guidelines
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC