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Pillar two
Home
Pillar two
PILLAR-TWO
Tax and the City review for February 2023
Zoe Andrews
Mike Lane
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 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
Zoe Andrews
Mike Lane
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.
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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