Clive Tietjen and Alison Lobb review three new discussion drafts published by the OECD.
David Harkness and Robert Sharpe explore potential areas of deficiency in the new CFC rules and their interaction with the Banking Code.
Praveen Gupta answers a question on a loan relationship between connected companies.
Peter Cussons examines the impact of the decision.
Chris Morgan provides your monthly review, including coverage of the decisions in Santander and Philips and Australia's Federal Budget.
Roopa Aitken and Hannah Tilson consider the implications of the Advocate General's opinion in the Philips case.
The Court of Appeal ruled unanimously in favour of the taxpayer in First Nationwide concerning dividends from share premium. Matthew Herrington reviews the wider implications.
Kunal Vyas and Kevin Cummings review the UK tax regime, and suggest that the often knee-jerk reaction of many originators and market participants to go offshore is, in many cases, unnecessary.
A special low rate of UK corporation tax on finance profits from overseas financing within multinational groups will offer a ‘very significant’ benefit to groups setting up a structure that represents, according to a leading tax expert, ‘almost government-approved tax avoidance’.
Companies should pay a fair rate of tax and ‘move vigorously towards the path of transparency’, the Labour peer and former newspaper publisher Lord Hollick told tax experts earlier this month, as campaigners renewed calls for country by country reporting (CBCR) by multinationals and claimed that