John Watson, former head of tax at Ashurst, with assistance of Martin Precious, reviews the options for reform of the international taxation of corporate profits, in view of the OECD's action plan on tackling base erosion and profit shifting.
By Priya Dutta
Chris Morgan reviews recent developments, including the recent CFC and dividend group litigation (Prudential Assurance Company Ltd), the AG’s opinion in Felixstowe and Emerging Market Series, and updates to tax rules in Brazil, Ireland and Norway.
By Andrew Goldstone & Jonathan Legg, Mishcon de Reya
Malcolm Finney answers a query on split-year residence and the sale of shares.
Residency: ‘distinct break’ from the UK
Despite a recent discussion draft from the OECD, the difficulties of characterisation of termination payments paid to internationally mobile employees are likely to continue, James Hill explains.
Michael Anderson and Samantha Wilson examine the recent High Court ruling on Prudential, the test case in the CFC and dividend GLO.
HMRC has published RDR1: Guidance Note: Residence, Domicile and the Remittance Basis, which replaces the previous guidance in HMRC6 and applies from 6 April 2013. Readers are also referred to the separate guidance in RDR3: Statutory Residence Test.