INTERNATIONAL TAXES

Financial institution notices represent a greater power for HMRC, but this does not mean that tax managers’ hands are tied, write David Haworth and Rose Swaffield (Freshfields).

Helen McGhee

Lynnette Bober

Helen McGhee and Lynnette Bober (Joseph Hage Aaronson) provide an overview of the new rules and highlight some key points to watch.

Tamar Ruiz

Matthew Mortimer

Matthew Mortimer and Tamar Ruiz (Mayer Brown) provide an overview of the tax treatment of derivatives, repo and stock loan transactions for UK companies.

Tim Sarson

The proposed US regulations on Corporate Alternative Minimum Tax, an important CJEU decision on state aid and the Irish Budget are among the recent developments reviewed by Tim Sarson (KPMG).

Dominic Robertson

Amaury de Galbert

Does the CJEU’s judgment in Apple signify a major shift in tax State aid cases? Or is Apple likely to be a one-off? Amaury de Galbert and Dominic Robertson (Slaughter and May) investigate.

Tim Sarson

The Irish Apple state aid case and the US electoral candidates respective tax policies are among the recent developments reviewed by Tim Sarson (KPMG).

Donald L. Korb

Andrew Solomon

Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.

Philip Baker KC

Unbridgeable divides? Recent developments do not bode well for a successful outcome to the process of reforming the international tax architecture, writes Philip Baker KC OBE (Field Court Tax Chambers).

Kyle Rainsford

In GE Financial Investments, the Upper Tribunal favoured the functional interpretation while the Court of Appeal favoured the territorial, writes Kyle Rainsford (Addleshaw Goddard).

Tim Sarson

Pressure grows for a global wealth tax. This and other recent developments in international tax are examined by Tim Sarson (KPMG).

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