Sarah Norton summarises the changes regarding real-time working of transfer pricing issues and Advanced Pricing Agreements, cost contribution agreements and share options
The Court of Appeal has handed down the latest judgment in the M&S group relief case. Alison Last assesses the impact of the decision.
Helen Lethaby reviews the latest developments, including anti-avoidance concerning manufactured overseas dividends.
Dominic Stuttaford and Ed Denny assess the impact of the Advocate General's Opinion in the case of National Grid Indus BV
Detailed proposals for reform of the controlled foreign companies regime do not reflect the government’s ‘high level aims’, according to the Chartered Institute of Taxation.
The new CTA 2010 s 27 (attribution to persons of rights and powers of their associates) inserted by FA 2011 is reflected in an updated Small Profits Rate and Marginal Relief Toolkit, HMRC announced.
Inter-company debt: whether a ‘loan relationship’
The de minimis mismatch, how to identify the group and relevant companies, clearing intercompany loans ... Robert Langston looks at five key issues that arise in practice concerning the debt cap rules