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Oecd
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Oecd
OECD
OECD pillar talk: Pillar Two looming; Pillar One a step closer
James Burton
Brin Rajathurai
Mitchell Fraser
Brin Rajathurai, James Burton and Mitchell Fraser (Allen & Overy) review last week’s OECD announcements on the two-pillar solution.
Pillar Two: compatibility of the UTPR with double tax treaties
Bezhan Salehy
Sarah Ling
Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.
Tax and the City review for February 2023
Mike Lane
Zoe Andrews
It is full steam ahead for implementation of the global minimum tax in the UK and the EU, report Mike Lane and Zoe Andrews (Slaughter and May).
International review for September 2022
Tim Sarson
Tim Sarson (KPMG) reviews the international landscape, including renewed impetus to implement Pillar Two and the latest US tax developments.
UK implementation of Pillar Two: where are we now?
Elena Rowlands
Jessica Kemp
Laura Hodgson
Laura Hodgson, Elena Rowlands and Jessica Kemp (Travers Smith) analyse the UK’s draft multinational top-up tax legislation and consider what developments are still to come.
‘Am I a shell?’ The new question facing EU entities
Laura Hodgson
Laura Hodgson (Travers Smith) explains why the proposed new rules may
require businesses to bolster the substance of their EU holding companies.
Does the international agreement on the OECD pillars mark the end of trade wars on digital taxes?
Lorand Bartels
Brin Rajathurai
The recent international agreement on the OECD’s two-pillar approach is intended to take unilateral digital tax measures off the table and put an end to these trade wars. But that does not necessarily mean there is no further role for trade law in this area, write Brin Rajathurai and Lorand Bartels (Freshfields Bruckhaus Deringer).
International review for August 2021
Tim Sarson
Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).
The OECD’s statement on international tax reform
James Chandler
Sandy Bhogal
Sandy Bhogal and James Chandler (Gibson, Dunn & Crutcher) review the proposed reforms allocating corporate profits to customer-heavy jurisdictions and imposing a global minimum tax rate.
Private client review for June 2021
Edward Reed
Mark Stichbury
Edward Reed and Mark Stichbury (Macfarlanes) provide this month’s review of developments affecting private clients.
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EDITOR'S PICK
GE Financial, treaty residence, and the meaning of ‘business’
Kyle Rainsford
1 /7
OECD pillar talk: Pillar Two looming; Pillar One a step closer
Brin Rajathurai
,
James Burton
,
Mitchell Fraser
2 /7
NICs investment zone reliefs for employers
3 /7
New transfer pricing records requirements
4 /7
UK adopts Pillar Two accounting changes
5 /7
M R Currell Ltd v HMRC
6 /7
Legislation day: draft Finance Bill 2024
7 /7
GE Financial, treaty residence, and the meaning of ‘business’
Kyle Rainsford
OECD pillar talk: Pillar Two looming; Pillar One a step closer
Brin Rajathurai
,
James Burton
NICs investment zone reliefs for employers
New transfer pricing records requirements
UK adopts Pillar Two accounting changes
M R Currell Ltd v HMRC
Legislation day: draft Finance Bill 2024
NEWS
Read all
Test4- GE Financial, treaty residence, and the meaning of ‘business
Test3- GE Financial, treaty residence, and the meaning of ‘business
Test- GE Financial, treaty residence, and the meaning of ‘business
Test2- GE Financial, treaty residence, and the meaning of ‘business
Treasury Committee calls for systematic review of tax reliefs
CASES
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Test4- GE Financial, treaty residence, and the meaning of ‘business
Test3- GE Financial, treaty residence, and the meaning of ‘business
Test- GE Financial, treaty residence, and the meaning of ‘business
Test2- GE Financial, treaty residence, and the meaning of ‘business
M R Currell Ltd v HMRC
IN BRIEF
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Test4- GE Financial, treaty residence, and the meaning of ‘business
Test3- GE Financial, treaty residence, and the meaning of ‘business
Test- GE Financial, treaty residence, and the meaning of ‘business
Test2- GE Financial, treaty residence, and the meaning of ‘business
Self’s assessment: Inheritance tax
MOST READ
Read all