Corporate reorganisations require analysis of company law issues as well as tax considerations. Paul Lester outlines the legal traps to avoid
Zach Citron explains why the tax department plays the star role in so many group reorganisations – and offers some practical tips
A well-structured group can yield a range of benefits. Sarah Churton examines the key building blocks
Rob Lant and Joel Phillips consider the options available for groups looking to undertake a demerger
The objective of holding multinationals to account in relation to tax planning strategies – one of six stated ‘possible objectives’ – was discounted by a group of tax experts and practitioners reporting to the OECD in April on the case for greater disclosure of tax information.
The Income Tax (Manufactured Overseas Dividends) (Amendment) Regulations, SI 2011/1787, amend SI 1993/2004 to take account of the reform of the taxation of foreign permanent establishments.
Bradley Phillips provides a one page overview of the CFC proposals set out in the 110 page consultation document
Jeanette Zaman examines the structure of the new regime and the proposed general purpose exemption, which is intended to replace the current motive test
Sara Luder considers the proposed CFC regime for finance and IP companies, asking whether it will turn the tide on corporate migrations