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CORPORATION TAX
Transfer pricing implications of Covid-19
Ken Almand
Paul Daly
Changes in transfer pricing policies may be required as a result of the impact
of Covid-19, as Ken Almand and Paul Daly (BDO) explain.
UK tax pitfalls of the foreign company
Laura Hoyland
Elizabeth Emerson
Laura Hoyland and Elizabeth Emerson (White & Case) explain the various bear-traps for a foreign company proposing to do business in the UK.
The Finance Bill 2020 changes to intangibles
Josh Lom
David Alexander
Josh Lom and
David Alexander (
Herbert Smith Freehills) consider the extent of the reforms to the
corporation tax treatment of intangible fixed assets.
Guarantees revisited
Stuart Pibworth
Jenny Doak
Jenny Doak and Stuart Pibworth (Weil, Gotshal & Manges) revisit some of the key UK corporation and withholding tax considerations to consider on guarantees of financial obligations.
The UK’s digital services tax: what’s changed
Michael Alliston
Judy Harrison
Michael Alliston and Judy Harrison (Norton Rose Fulbright) consider what's new in HMRC's guidance and how the Finance Bill legislation has changed since the earlier draft.
The disguised remuneration regime unpacked
Karen Cooper
Karen Cooper (Cooper Cavendish) sets out the rules, tax treatment and the impact of legislation on EBTs and remuneration planning.
Going GloBal: the OECD’s consultation on pillar two
Brin Rajathurai
Murray Clayson
Experts at Freshfields Bruckhaus Deringer examine the OECD's pillar two proposals which could have a fundamental impact on the way all multinationals are taxed.
Is the DST compatible with the UK’s international obligations?
Rupert Shiers
Jonathan T Stoel
The UK DST in its current form may well breach the UK’s obligations under double tax treaties, international trade law, or both, write Rupert Shiers and Jonathan T Stoel (Hogan Lovells).
How to choose your holding company location
Charles Osborne
Sara Luder
Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.
The OECD’s new approach to pillar one: the view from BIAC
William Morris
BIAC does not for a moment underestimate the difficulty of reaching a broad and deep agreement on pillar one.
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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
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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
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Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
Autumn Budget 2024: IHT winners and losers
UK signs new double tax treaty with Romania