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Pillar two
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Pillar two
PILLAR-TWO
International review for March 2024
Tim Sarson
Tim Sarson (KPMG) reviews the Biden Administration’s FY 2025 tax proposals and the OECD’s new guidance on Amount B of Pillar One.
Pillar Two compliance: the view from the 100 Group Tax Committee
Dominic Mathon
Writing on behalf of the 100 Group Tax Committee, Dominic Mathon reports views from the Committee's members on how much additional tax they expect to pay as a result of Pillar Two - and the associated compliance costs.
International review for January 2024
Tim Sarson
Tim Sarson (KPMG) reports on a flurry of activity across the international tax world and looks ahead at what to expect in 2024.
Tax in 2024 and beyond
Bill Dodwell
Increased digital reporting, the implementation of Pillar Two, potential further reforms to pensions tax... Bill Dodwell, former Tax Director of the Office of Tax Simplification, looks at what’s in store for tax in the year ahead.
Tax and the City review for January 2024
Zoe Andrews
Mike Lane
Consultation responses to the VAT treatment of fund management services,
Euromoney
on the purpose test, recent developments on Pillar Two, and a report on the tax contribution of the UK banking sector are examined by Mike Lane and Zoe Andrews (Slaughter and May).
International review for November 2023
Tim Sarson
Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).
International review for October 2023
Tim Sarson
The international tax world is still dominated by BEPS 2.0 developments,
reports Tim Sarson (KPMG). This article includes an update on the national
implementation of Pillar Two.
International review for September 2023
Tim Sarson
This month’s review by Tim Sarson (KPMG) includes the latest batch of OECD BEPS releases and Pillar Two implementation updates from around the world.
Multinational top-up tax: an overview
Tamar Ruiz
Matthew Mortimer
The multinational top-up tax regime appears to be endlessly complicated. Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine ten aspects of the regime, including a ten-step process to navigating the rules.
Judicial developments in recent treaty cases
Constantine Christofi
David Goldberg QC
Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).
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7
EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
Tax Journal authors for November 2024
HMRC manual changes: 6 December 2024
Exchequer Secretary committed to MTD timetable following ‘robust’ conversations with HMRC
MTD: catching up with digital records
No new side hustle tax, HMRC confirm
CASES
Read all
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
L v HMRC
Other cases that caught our eye: 6 December 2024
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
IN BRIEF
Read all
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
Read all
The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
Stage One Creative Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others