Multinational ‘tax dodges’ are estimated to account for over half of all illicit capital flight from developing countries, the European Network on Debt and Development (Eurodad), a network of NGOs from 19 European countries, has claimed.
Nick Farmer and Steve Hoare recap the rules in determining whether an overseas establishment is a PE, and the implications.
Five leading tax professionals, including HMRC's Judith Knott, took part in a roundtable discussion on UK tax competitiveness. Much of the discussion, chaired by John Overs, concerned CFC reform and the potential ‘gateway’ test to filter cases out of the regime.
Robert Langston answers a reader's question on the international transfer of property.
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