Peter Jackson (Taylor Wessing) answers a query on a group restructuring to assist the refinancing of existing debt
CFC and dividend group litigation: outstanding issues
Peter Cussons examines the potential EU law and international issues facing the UK's diverted profits tax.
Simon Whitehead (Joseph Hage Aaronson) examines the High Court judgment in the FII GLO handed down on 18 December.
In the first of a new series, Allan Cinnamon provides a global review of tax treaty developments, including the UK’s DPT.
Dominic Robertson (Slaughter and May) reports on the likely changes needed to group structures in light of BEPS, state aid challenges and the diverted profits tax
Hey, a new tax. As a tax adviser, that sounds like pretty good news. (Shame it is so bad for the country, but that's politics for you).
It is clear that the government feels the need to ‘do something’. However, it is much less clear that the diverted profits tax proposals is the best thing to do, as Heather Self (Pinsent Masons) explains.
Which taxpayers should review their position following the CJEU decision in EC v UK regarding TCGA 1992 s 13)? Peter Cussons, international corporate tax partner at PwC, considers the implications for taxpayers and believes further amendments to the legislation could be possible.
Intra-group acquisition of loan notes and the related party rule