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GROUPS


When structuring a UK acquisition, there are a myriad of tax issues to consider, as Helena Kanczula (BKL) explains.
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.
The progress of the European Commission’s proposal for public country by country reporting depends on whether it is regarded primarily as a tax or a company law matter. 
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).
Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.
BIAC does not for a moment underestimate the difficulty of reaching a broad and deep agreement on pillar one. 
Ashley Greenbank and Penny Van den Brande (Macfarlanes) consider the UK tax consequences for businesses considering moving assets or functions out of the UK, whether by a change of residence of a UK company, the insertion of a new, non-UK, holding company or the relocation of specific assets and functions
Groups will need to review their existing arrangements and consider appropriate jurisdictions for new investments, write Emily Osborne and Hilary Barclay (Stephenson Harwood).

Investigations are taking longer, but HMRC’s new facility offers multinationals the prospect of quicker resolution for certain disputes.

What is the tax and accounting treatment of the repayment of a contributed surplus from a subsidiary company to a parent company and how should this be treated in the parent company’s books? Jackie Wheaton (BDO) considers the key points.

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