INTRA-GROUP

The UK’s approach may require taxpayers to take a leap of faith that the final legislation will align with the GloBE rules, write Chris Sanger and Jack Gifford (EY).

Lucy Urwin

Gregory Price

Gregory Price and Lucy Urwin (Macfarlanes) discuss the challenges of dealing with LLPs in the context of M&A and group reorganisations in light of recent case law.

Gary Barnett

Bryn Reynolds

Gary Barnett and Bryn Reynolds (Simmons & Simmons) cover a number of decisions which indicate the existence of a separate but parallel universe of VAT.

Gary Barnett

Bryn Reynolds

Recent VAT developments that matter, examined by Bryn Reynolds and Gary Barnett (Simmons & Simmons).

Natasha Kaye

Reshma David

Natasha Kaye and Reshma David (Cooley) examine the scope of the close company indirect loan to participator rule in CTA 2010 s 459.

Matthew Hodkin

Matthew Hodkin (Norton Rose Fulbright) considers some enlightening detail on a new proposal to introduce a wider exemption than first contemplated by the consultation process.

Jonathan Cooklin

Dominic Foulkes

With the UK’s continuing attractiveness as a holding company tax jurisdiction, Jonathan Cooklin and Dominic Foulkes (Davis Polk) consider the scope of technical UK tax issues that have a direct bearing on the drafting of merger agreements and related documents which implement these transactions.

Dominic Robertson

Isabel Taylor

Dominic Robertson and Isabel Taylor (Slaughter and May) consider the Apple state aid decision and its impact on other businesses.

Heather Self

Heather Self (Pinsent Masons) examines the First-tier Tribunal case of Stagecoach, the latest case involving a complex intra-group financing scheme.

Jeanette Zaman

Jeanette Zaman (Slaughter and May) considers the draft legislation on hybrid mismatch arrangements and discusses their application to commercial transactions and the potential significance of the imported mismatch rules.

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