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Pillar two
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Pillar two
PILLAR-TWO
OECD pillar talk: Pillar Two looming; Pillar One a step closer
Brin Rajathurai
,
James Burton
,
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.
International review for June 2023
Tim Sarson
Pillar Two is gathering further momentum with announcements this month from nine territories, reports Tim Sarson (KPMG).
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
Rhiannon Kinghall Were
While a coordinated roll-out of rules was once an aspiration, the reality is
anything but, explain Ashley Greenbank and Rhiannon Kinghall Were
(Macfarlanes).
The saga continues: implementing Pillar Two in the UK
Chris Sanger
Jack Gifford
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).
International review for April 2023
Tim Sarson
Pillar Two implementation is gaining traction around the world, reports
Tim Sarson (KPMG).
International review for March 2023
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
Pillar Two and the GloBE rules
James Burton
,
Ellen Birkemeyer
,
Naomi Lawton
,
Mitchell Fraser
James Burton, Ellen Birkemeyer, Naomi Lawton and Mitchell Fraser (Allen & Overy) provide a 20 questions guide.
International review for February 2023
Tim Sarson
The OECD’s much-awaited Pillar Two administrative guidance is among the recent developments reviewed by Tim Sarson (KPMG).
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).
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5
EDITOR'S PICK
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
1 /7
What happens at a tribunal hearing?
Anne Redston
2 /7
Schedule 36: a stitch in time
Keith Gordon
3 /7
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
,
Cécile Perrault
4 /7
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
,
Rhiannon Kinghall Were
5 /7
Tax Administration and Maintenance Day: report
6 /7
Pension planning after the Budget
Mike J Haynes
7 /7
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
What happens at a tribunal hearing?
Anne Redston
Schedule 36: a stitch in time
Keith Gordon
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
,
Cécile Perrault
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
,
Rhiannon Kinghall Were
Tax Administration and Maintenance Day: report
Pension planning after the Budget
Mike J Haynes
NEWS
Read all
Treasury Committee calls for systematic review of tax reliefs
NICs investment zone reliefs for employers
R&D claim requirements confirmed
New transfer pricing records requirements
HMRC issues clarifications on SBAs
CASES
Read all
M R Currell Ltd v HMRC
Sonder Europe Ltd v HMRC
TP v Administration de l’Enregistrement, des Domaines et de la TVA
Ebuyer (UK) Ltd v HMRC
Other cases that caught our eye: 28 July 2023
IN BRIEF
Read all
Self’s assessment: Inheritance tax
When does a payment constitute a distribution?
OECD inclusive framework publishes outcome statement on Pillar One and Pillar Two
Legislation day: practitioners' views
Challenging information notices
MOST READ
Read all