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Corporate taxes
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CORPORATE TAXES
Notification of uncertain tax treatments: round two
Gregory Price
Jack Slater
Gregory Price and Jack Slater (Macfarlanes) discuss the latest proposals
facing large businesses that require response by 1 June.
Re-born in the USA
Gregory Price
Ashley Greenbank
Rhiannon Kinghall Were
Five key implications of the US proposals on the OECD’s tax plans.
Self's assessment: signs of a ceasefire in the digital trade war?
Heather Self
In our continuing series, Heather Self reviews tax issues that make the headlines in the national press. This week, the impact of the new US proposals on international tax reform.
Finance Bill 2021: hybrid mismatch rules version 2.0
Claudine Fox
Nick Evans
The UK hybrid rules impose double taxation as currently enacted, explain
Nick Evans and Claudine Fox (Baker McKenzie). Changes will be made, but
do they go far enough?
Tax day: expectations dashed
Rhiannon Kinghall Were
Rhiannon Kinghall Were (Macfarlanes) examines the areas of interest from 'tax day' 2021.
The changing landscape for non-resident corporate landlords
Claire Lillie
Claire Lillie (EY) examines the administrative and technical considerations
for non-resident corporate landlords as they complete their transition towards
corporation tax.
Seven lessons from Clipperton
Oliver Marre
A recent tribunal decision provides lessons on the settlement provisions,
Ramsay
and piercing the corporate veil, writes barrister Oliver Marre
(5 Stone Buildings).
The problem with HMRC clearances
Martin Walker
Mark Bevington
With HMRC increasingly challenging and rescinding clearances, the certainty
provided by pre-clearing transactions has faded, write Martin Walker and
Mark Bevington (ADE Tax).
International tax and treasury issues in 2021
Andrew Cotterill
John Webb
Mairead Murphy
Interest deductibility, foreign exchange, withholding taxes... John Webb,
Andrew Cotterill and Mairead Murphy (PwC) review the key UK tax
considerations for financing transactions and global treasury functions.
Back to basics: the UK patent box regime
Clare Anderson
Clare Anderson (Smith & Williamson) explains how the regime works and
the process of claiming.
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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
EOT tax relief too narrow, suggests CIOT
Tax reliefs confirmed for special tax sites in Wales
Updated advisory fuel rates published
IHT should apply equally across all assets, says IFS
Scottish aggregates tax on the horizon
CASES
Read all
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
IN BRIEF
Read all
Refinitiv: not so clear cut
The complexities of APR and IHT for family farms
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
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