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Corporate taxes
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CORPORATE TAXES
The two-pillar framework: what does the October statement tell us?
Phil Greenfield, Chloe O’ Hara and Giorgia Maffini (PwC) examine the key changes in the Inclusive Framework’s new statement.
Tax and the City review for October 2021
Zoe Andrews
Mike Lane
The impact of the ruling in
Almacantar
, the latest on the economic crime levy and state aid issues are among the developments covered in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
The war on holding companies and the return of withholding taxes
Gregory Price
Sarah Ling
BEPS 2.0 and ATAD 3 represent the latest challenge to the tax status of holding companies, renewing focus on issues of substance and withholding taxes, write Gregory Price and Sarah Ling (Macfarlanes).
HMRC’s draft guidance: adding further uncertainty to uncertain tax treatments
Kate Alexander
Nick Evans
It was hoped HMRC’s guidance would clarify the interpretation of the vaguer aspects of the statute, but the current draft offers limited practical assistance, write Kate Alexander and Nick Evans (Baker McKenzie).
Tax and the City review for September 2021
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
A new era for the UK patent box
Andy Jacott
Sarah Lord
All companies claiming patent box relief are subject to the new nexus regime
from 1 July 2021. Sarah Lord and Andy Jacott (Deloitte) explain how it works.
Tax and the City review for July 2021
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) report on the recent
developments, including some encouraging findings on the UK’s position as a
leading centre for financial services investment.
Debt restructuring: deemed releases
Paul Pritchard
The impact of the pandemic may necessitate a financial restructuring of a company’s liabilities. Paul Pritchard (FTI Consulting) provides a practical guide to the tax issues surrounding deemed release rules.
Tax and the City review for June 2021
Zoe Andrews
Mike Lane
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
Debt restructuring: releases
Paul Pritchard
Companies emerging from the pandemic may undertake a debt restructuring.
Paul Pritchard (FTI Consulting) discusses current tax issues with debt
releases.
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300
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