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CORPORATION TAX
Transfer pricing implications of Covid-19
Ken Almand
Paul Daly
Changes in transfer pricing policies may be required as a result of the impact
of Covid-19, as Ken Almand and Paul Daly (BDO) explain.
UK tax pitfalls of the foreign company
Laura Hoyland
Elizabeth Emerson
Laura Hoyland and Elizabeth Emerson (White & Case) explain the various bear-traps for a foreign company proposing to do business in the UK.
The Finance Bill 2020 changes to intangibles
Josh Lom
David Alexander
Josh Lom and
David Alexander (
Herbert Smith Freehills) consider the extent of the reforms to the
corporation tax treatment of intangible fixed assets.
Guarantees revisited
Stuart Pibworth
Jenny Doak
Jenny Doak and Stuart Pibworth (Weil, Gotshal & Manges) revisit some of the key UK corporation and withholding tax considerations to consider on guarantees of financial obligations.
The UK’s digital services tax: what’s changed
Michael Alliston
Judy Harrison
Michael Alliston and Judy Harrison (Norton Rose Fulbright) consider what's new in HMRC's guidance and how the Finance Bill legislation has changed since the earlier draft.
The disguised remuneration regime unpacked
Karen Cooper
Karen Cooper (Cooper Cavendish) sets out the rules, tax treatment and the impact of legislation on EBTs and remuneration planning.
Going GloBal: the OECD’s consultation on pillar two
Brin Rajathurai
Murray Clayson
Experts at Freshfields Bruckhaus Deringer examine the OECD's pillar two proposals which could have a fundamental impact on the way all multinationals are taxed.
Is the DST compatible with the UK’s international obligations?
Rupert Shiers
Jonathan T Stoel
The UK DST in its current form may well breach the UK’s obligations under double tax treaties, international trade law, or both, write Rupert Shiers and Jonathan T Stoel (Hogan Lovells).
How to choose your holding company location
Charles Osborne
Sara Luder
Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.
The OECD’s new approach to pillar one: the view from BIAC
William Morris
BIAC does not for a moment underestimate the difficulty of reaching a broad and deep agreement on pillar one.
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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
Tax Journal authors for November 2025 testing
HMRC manual changes: 6 December 2024
Exchequer Secretary committed to MTD timetable following ‘robust’ conversations with HMRC
MTD: catching up with digital records
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