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CORPORATION TAX


Ashley Greenbank and Penny Van den Brande (Macfarlanes) consider the UK tax consequences for businesses considering moving assets or functions out of the UK, whether by a change of residence of a UK company, the insertion of a new, non-UK, holding company or the relocation of specific assets and functions
Ryan Bebbington and Daniel Sladen (PKF-Francis Clark) provide a reference guide to the rules and highlights the key areas to consider for those advising SMEs

Julian Feiner (Clifford Chance) discusses the taxpayers' resounding victory at the Upper Tribunal in the company residency case of Development Securities plc and others v HMRC

Alun Oliver (E³ Consulting) discusses the relief to UK corporation taxpayers that alleviates the costs in remediating contaminated or long-term derelict sites. 

Investigations are taking longer, but HMRC’s new facility offers multinationals the prospect of quicker resolution for certain disputes.

The OECD's programme of work subtly recasts the two pillars proposed in its earlier consultation, as Brin Rajathurai and Murray Clayson (Freshfields Bruckhaus Deringer) explain.

Many corporates now have a lower appetite for tax risk, and taxpayers are concerned about HMRC's increasingly interventionist approach.

Three recent tax-related developments in the insolvency and restructuring sphere.

What is a just and reasonable apportionment of profits as an alternative to time apportionment?
Paul Farmer and Francisco Alvarez (Joseph Hage Aaronson) analyse the European Commission’s findings and the next steps to be taken.
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