CORPORATION TAX

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.

Jessica Hocking

Kate Ison

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

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

Chris Lallemand

What is a just and reasonable apportionment of profits as an alternative to time apportionment?

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.

Thomas Dalby

Thomas Dalby (Gabelle) reviews an Upper Tribunal decision on CT deductions for share options.

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.

Lorna Jordan

Alison Hughes

Lorna Jordan and Alison Hughes (KPMG) consider some of the practical issues that can arise when claiming corporation tax deductions in respect of share incentive arrangements.

Gregory Price

Rhiannon Kinghall Were

Gregory Price and Rhiannon Kinghall Were (Macfarlanes) consider how companies can develop an approach to tax within a wider framework for corporate governance.

Paul Morton

Paul Morton (The Office of Tax Simplification) reports on the tax issues that the OTS has considered over the last two years and some future strategies.

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