CONTROLLED-FOREIGN-COMPANIES

Paul Davison

The judgment reads as something of a ‘whitewash’, supporting the Commission on every ground, write Paul Davison and Helen Buchanan (Freshfields Bruckhaus Deringer).

Tim Sarson

Delay and a lack of political consensus on BEPS feature in this month’s review by Tim Sarson (KPMG).

Michael Anderson

Joseph Irwin

Michael Anderson and Joseph Irwin (Joseph Hage Aaronson) examine the recent High Court judgment that found largely in favour of HMRC.

Zoe Wyatt

Tom Wesel

Tom Wesel and Zoe Wyatt (Milestone International Tax Partners) review the revised EC’s Anti-Tax Avoidance Directive which will soon be adopted by the European Parliament to ensure a consistent and uniform implementation of BEPS recommendations across the EU.

David Harkness and Robert Sharpe consider the CJEU judgment in SCA Group Holding BV and its significance to the UK CFC rules

Chris Morgan

Chris Morgan reviews recent developments in the international tax sphere, including: the two changes to the CFC exemption contained in FB 2014; a summary of the CJEU’s rejection of the UK’s FTT challenge; proposed amendments to the EU’s Parent-Subsidiary Directive; and updates from India and Germany

Chris Morgan

Chris Morgan reviews recent developments in international tax