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International taxes
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International taxes
INTERNATIONAL TAXES
Finance Bill 2021: hybrid mismatch rules version 2.0
Claudine Fox
Nick Evans
The UK hybrid rules impose double taxation as currently enacted, explain
Nick Evans and Claudine Fox (Baker McKenzie). Changes will be made, but
do they go far enough?
International holding structures: are they structurally sound?
Creina Kane
Jenni Bullivant
Aaron Mehta
Jenni Bullivant, Creina Kane and Aaron Mehta (PwC) reflect on the host of international tax issues and complexities associated with international holding structures as a consequence of the continually changing external landscape.
International review for March 2021
Tim Sarson
Tim Sarson (KPMG) reviews recent overseas developments, including a significant breakthrough on public country by country reporting.
The European Commission’s ‘digital levy’
Jennifer Maskell
Richard Sultman
The European Commission has a new ‘digital levy’ initiative, pending
international consensus on digital taxation. Jennifer Maskell and Richard
Sultman (Cleary Gottlieb Steen & Hamilton) consider how it might look.
International review for February 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
International tax and treasury issues in 2021
Andrew Cotterill
John Webb
Mairead Murphy
Interest deductibility, foreign exchange, withholding taxes... John Webb,
Andrew Cotterill and Mairead Murphy (PwC) review the key UK tax
considerations for financing transactions and global treasury functions.
Brexit: tax competition between the UK and the EU27
David Haworth
Alison Dickie
Alison Dickie and David Haworth (Freshfields Bruckhaus Deringer)
consider whether the Brexit deal paves the way for a low-tax and less regulated
UK tax environment.
International tax cooperation with the EU post-Brexit
Jason Collins
Catherine Robins
Now that the Brexit transition period has ended, where does this leave the
UK’s administrative cooperation with other jursidictions, ask Jason Collins
and Catherine Robins (Pinsent Masons).
International review for January 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
2020: five trends in international tax
Chris Sanger
Chris Sanger (EY) considers five key trends that have moved forward over
2020 and are building up pressure for action in the future.
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213
EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
EOT tax relief too narrow, suggests CIOT
Tax reliefs confirmed for special tax sites in Wales
Updated advisory fuel rates published
IHT should apply equally across all assets, says IFS
Scottish aggregates tax on the horizon
CASES
Read all
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
IN BRIEF
Read all
Refinitiv: not so clear cut
The complexities of APR and IHT for family farms
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
UK signs new double tax treaty with Romania
Autumn Budget 2024: IHT winners and losers