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Pillar two
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Pillar two
PILLAR-TWO
International review for January 2023
Tim Sarson
Tim Sarson (KPMG) provides a recap of recent Pillar One and Two developments, and looks ahead to what’s in store throughout 2023.
Tax and the City review for November 2022
Mike Lane
Zoe Andrews
This month’s round-up, by 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.
Pillar two and the future of tax incentives
Bezhan Salehy
Bezhan Salehy (Macfarlanes) considers how countries may maintain their tax competitive standing after the implementation of pillar two.
The impact of the OECD’s pillar two on international M&A
Brin Rajathurai
May Smith
Brin Rajathurai and May Smith (Freshfields Bruckhaus Deringer) explain how pillar two will have an uneven impact on the attractiveness of different target companies and potentially favour certain types of bidders over others.
International review for June 2022
Tim Sarson
Delay and a lack of political consensus on BEPS feature in this month’s review
by Tim Sarson (KPMG).
International review for May 2022
Tim Sarson
The latest on BEPS, tax transparency and transfer pricing, reviewed by Tim Sarson (KPMG).
How pillar two attacks multinationals’ high tax subsidiaries
Mark Bevington
Mark Bevington (ADE Tax) highlights the ‘traps’ on the operation of the pillar two model rules which might generate a tax charge when none was expected.
International review for March 2022
Tim Sarson
OECD commentary on the pillar two model rules and the responses to the pillar one public consultations are among the recent developments examined by Tim Sarson (KPMG).
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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
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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
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
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
Self’s assessment: Inheritance tax
MOST READ
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