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CROSS BORDER


The Commission neatly shifts its position on the UK’s CFC rules, writes Paul Davison (Freshfields Bruckhaus Deringer).

Substantial changes have been made to the profit fragmentation anti-avoidance since the original consultation was published, writes Mark Saunders (PwC).

Timothy Lyons QC (39 Essex Chambers) considers the interaction of our laws with Europe since 1973 and looks to what the future might hold.
 

Examining the CBC reporting notification requirements in the UK.

Michael Cullers and Robert O’Hare (Squire Patton Boggs) examine a US Supreme Court decision that could have far-reaching ramifications for international entities carrying on business in the US.
 
Brin Rajathurai and Helen Gunson (Freshfields Bruckhaus Deringer) consider practical issues surrounding the new cross-border disclosure rules.
 
Michael Conlon QC (Temple Tax Chambers) considers what can be learnt from the recent Court of Appeal decision.
 
Gideon Sanitt and Batanayi Katongera (Macfarlanes) review the state of play and the current steps being taken by the UK to implement the measures.
 

Melissa Geiger and Matt Whipp (KPMG) provide some guidance for corporate groups on what they should be doing next.

Deal or no deal? Liesl Fichardt and Karabeth Ovenden (Quinn Emanuel Urquhart & Sullivan) consider practical points for companies which have received assessments that appear to disregard tax stabilisation provisions.
 
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