INTERNATIONAL TAXES

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).

Robert Langston

Robert Langston (Saffery) explains why it is necessary to consider international tax principles, such as entity classification and transfer pricing, alongside the disguised investment management fee rules.

Tim Sarson

Your monthly review of latest developments, by Tim Sarson (KPMG).

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) explains that the Upper Tribunal has largely eschewed the FTT’s extensive reliance on UK domestic law cases on ‘purpose’ when determining whether a treaty anti-abuse provision applies.

Lavina Hassasing

Alistair Nichol

The expected impact of the new Pillar Two regime is starting to unfold as the first UK groups have filed their calendar year-end consolidated accounts, write Alistair Nichol and Lavina Hassasing (Evelyn Partners).

Will Timbrell

Kyra Motley

There is no equivalent to a Foundation registered with the Dubai International Finance Centre Registrar of Companies under English law. How then should they be treated for UK tax purposes? Kyra Motley and Will Timbrell (Boodle Hatfield) investigate.

Christopher Eames

A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.

Tim Sarson

The Advocate General’s opinion on the CFC Finco exemption state aid case, new US regulations and an update on Pillar Two are among the developments in this month’s review by Tim Sarson (KPMG).

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