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COMPLIANCE


The OECD's programme of work subtly recasts the two pillars proposed in its earlier consultation, as Brin Rajathurai and Murray Clayson (Freshfields Bruckhaus Deringer) explain.

My way or the highway will not lead to a longer-term solution, writes Deeksha Rathi (Slaughter and May).

Many corporates now have a lower appetite for tax risk, and taxpayers are concerned about HMRC's increasingly interventionist approach.

The Court of Appeal has recently interpreted the MSC legislation more widely than expected, paving the way for HMRC to target arrangements previously thought to be low risk, as Kevin Barrow and Ian Hyde (Osborne Clarke) explain.
Tm Sarson (KPMG) reviews the latest developments that matter.

Three recent tax-related developments in the insolvency and restructuring sphere.

What is a just and reasonable apportionment of profits as an alternative to time apportionment?
Hybrid capital instruments technical noteFA 2019 repealed and replaced the regulatory capital securities regime from 1 January 2019 with a new hybrid capital instrument (HCI) regime.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...
Thomas Dalby (Gabelle) reviews an Upper Tribunal decision on CT deductions for share options.
What is and is not included in a self-assessment? Michael Avient examines the taxpayer victory at the Supreme Court on a carry back loss claim.
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