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Home
Corporate taxes
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Corporate taxes
CORPORATE TAXES
Profit recognition under GloBE and domestic rules: it’s all in the timing
Bezhan Salehy
Timing differences could affect a group’s effective tax rate as much as permanent differences do, writes Bezhan Salehy (Macfarlanes).
Tax and the City review for January 2022
Zoe Andrews
Mike Lane
The consultation on hedging risks for future share transactions and the FTT
decision in
Hargreaves
are some of the recent developments reviewed by
Mike Lane and Zoe Andrews (Slaughter and May).
Purpose and logic: Dunsby as a very modern tax case
Oliver Marre
Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005.
UK corporate re-domiciliation: time to make a move?
Jill Gatehouse
Josh Critchlow
Alison Dickie
Jill Gatehouse, Josh Critchlow and Alison Dickie (Freshfields Bruckhaus Deringer) explore some of the interesting questions about the tax consequences of the proposed regime.
UK loan structures: changes to the anti-hybrid rules
Matthew Mortimer
Kirsten Hunt
Matthew Mortimer and Kirsten Hunt (Mayer Brown) consider the application to UK loan structures of recent changes to the UK’s anti-hybrid rules.
The UK’s new qualifying asset holding company regime
Elena Rowlands
Ian Zeider
Emily Clark
Emily Clark, Elena Rowlands and Ian Zeider (Travers Smith) give an overview of, and their verdict on, the QAHC legislation in the Finance Bill.
SPACs in the City: the tax take
Enda Kerin
Jenny Doak
How friendly is the City’s tax environment when it comes to SPACs? Jenny Doak and Enda Kerin (Weil, Gotshal & Manges) examine what SPAC transactions involve and the key UK tax considerations that can arise.
Tax and the City review for November 2021
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) consider Autumn Budget/Finance Bill measures relevant to financial institutions and the latest on international tax reform.
Taxation of loan transfers
David Southern QC
David Southern QC (Field Court Tax Chambers) provides a guide to the tax consequences of loan transfers.
The two-pillar framework: what does the October statement tell us?
Phil Greenfield, Chloe O’ Hara and Giorgia Maffini (PwC) examine the key changes in the Inclusive Framework’s new statement.
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300
EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
HMRC manual changes: 22 November 2024
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
UK signs new double tax treaty with Romania
Autumn Budget 2024: IHT winners and losers