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
The Chartered Institute of Taxation has raised with HMRC several concerns regarding draft legislation designed to counter a tax avoidance scheme, disclosed by Barclays, which sought to avoid the charge on ‘deemed releases’ of loan relationships.
Sara-Jane Donovan and Jennifer Pearce examine the latest update from the government on the new controlled foreign companies regime. Is the gate now open for multinationals?
Chris Harrison and Ben Brown examine the key corporation tax deductibility and VAT recovery issues on M&A deals.
An updated ‘Gateway’ features in HM Treasury’s latest update on CFC reform, published yesterday.
James Wilson sets out a risk-based approach to the rules.