CROSS BORDER

David Wren Reinhart Devisscher Paul Radcliffe

Paul Radcliffe, David Wren and Reinhart Devisscher (EY) consider the next steps for the EU to develop this model, and some key areas which may need to be contemplated in light of the European Commission’s upcoming consultation.

Dominic Stuttaford

Greg Branagan

Two recent decisions have sought to clarify the extent to which the EU freedom of establishment and of the movement of capital were restricted in light of various UK legislative provisions dealing with cross-border transactions and/or operations, as Dominic Stuttaford and Greg Branagan (Norton Rose Fulbright) explain.

Sandy Bhogal

Avi Kaye

Sandy Bhogal and Avi Kaye (Gibson, Dunn & Crutcher) explain the extent to which the UK government has curtailed existing reporting obligations.

Steve Wade

Sarah Hewson

Sarah Hewson and Steve Wade (EY) examine PAYE obligations and how any UK employment tax risks can be mitigated.

Charles Osborne

Sara Luder

Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.

Rory Mullan

Rory Mullan (Old Square Tax Chambers) examines two cases that demonstrate the importance of establishing the fundamental requirements of the TOAA code before a charge can be imposed.

William Morris

BIAC does not for a moment underestimate the difficulty of reaching a broad and deep agreement on pillar one.

Matthew Hodkin

Susie Brain

Matthew Hodkin and Susie Brain (Norton Rose Fulbright) consider HMRC's proposed approach to implementation and how reporting is likely to work within the context of the UK tax system.

Brin Rajathurai

Murray Clayson

The OECD's programme of work subtly recasts the two pillars proposed in its earlier consultation, as Brin Rajathurai and Murray Clayson (Freshfields Bruckhaus Deringer) explain.