James Wilson sets out a risk-based approach to the rules.
Mike Lane explains why the regime may be susceptible to challenge under EU law.
Aurell Taussig provides a flowchart on the new regime.
Martin Lambert and Zoe Wyatt provide a practical guide.
Michael Bird and Jonathan Bridges examine IP issues.
From Kevin Ashman, Tony Beare, Andrew Boucher, David Clissitt, Elizabeth Conway, Jonathan Cooklin, David Harkness, Robert Edwards, Aurell Taussig, Duncan Whitecross, James Wilson, Mark Edwards, Paul Morton and David Smith.
Chris Morgan provides this month’s briefing on international matters, including the latest on FATCA developments.
In this month's briefing, Helen Lethaby reviews the latest CFC developments, the decision of the Indian Supreme Court in Vodafone, and a recent Tribunal decision concerning equipment leasing.
HM Treasury has published an update and more draft legislation dealing with reform of the controlled foreign companies (CFC) rules. Two circumstances have been identified in which a full, rather than partial, finance company exemption will be offered.