GROUPS

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

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.

The OECD's programme of work subtly recasts the two pillars proposed in its earlier consultation, as Brin Rajathurai and Murray Clayson (Freshfields Bruckhaus Deringer) explain.

Three recent tax-related developments in the insolvency and restructuring sphere.