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Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
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).
Pillar Two: assessing the impact on the UK FTSE 100
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).
Pillar Two compliance: the view from the 100 Group Tax Committee
Dominic Mathon
Writing on behalf of the 100 Group Tax Committee, Dominic Mathon reports views from the Committee's members on how much additional tax they expect to pay as a result of Pillar Two - and the associated compliance costs.
International tax cooperation: the UN’s call for greater inclusivity and effectiveness
Sarah Blakelock
The UN is demanding a greater role in setting the global tax policy agenda,
but some countries have questioned whether this undermines the OECD/G20
Inclusive Framework discussions. Sarah Blakelock reports.
Reviewing HMRC’s consultation on transfer pricing reform
Bezhan Salehy
Deep Shah
Bezhan Salehy and Deep Shah (Macfarlanes) review the government’s extensive package of proposals that touch most areas of the UK’s transfer pricing, permanent establishment and diverted profits tax legislation.
International review for June 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
Self's assessment: signs of a ceasefire in the digital trade war?
Heather Self
In our continuing series, Heather Self reviews tax issues that make the headlines in the national press. This week, the impact of the new US proposals on international tax reform.
Taxation of the life sciences sector
Gary Ashford
Gary Ashford (Harbottle and Lewis) examines some of the tax issues facing those operating in the industry.
Taxation of credit funds: from one crisis to another
Lily Teh
Will Smith
Will Smith and Lily Teh (
White & Case) consider
some of the major trends and tax issues relevant to the establishment and operation of credit funds.
Self’s assessment: a digital trade war?
Heather Self
In our continuing series, Heather Self examines tax issues reported in the national media. This week, following news that the US has suggested halting multinational discussions on the OECD’s ‘pillar one’ digital tax proposals, are we heading for a tax trade war?
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14
EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
Tax Journal authors for November 2024
HMRC manual changes: 6 December 2024
Exchequer Secretary committed to MTD timetable following ‘robust’ conversations with HMRC
MTD: catching up with digital records
No new side hustle tax, HMRC confirm
CASES
Read all
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
L v HMRC
Other cases that caught our eye: 6 December 2024
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
IN BRIEF
Read all
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
Read all
The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
Stage One Creative Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others