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GROUPS


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
Groups will need to review their existing arrangements and consider appropriate jurisdictions for new investments, write Emily Osborne and Hilary Barclay (Stephenson Harwood).

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.

What is a just and reasonable apportionment of profits as an alternative to time apportionment?
Paul Farmer and Francisco Alvarez (Joseph Hage Aaronson) analyse the European Commission’s findings and the next steps to be taken.
One of the more interesting part of this years Finance Act, from my perspective, is that an anomaly that arose in FA 2011 has finally been fixed in FA 2019.Following a review of the impact of capital gains on companies after the 2010 Budget,...
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