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International taxes
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INTERNATIONAL TAXES
OBBBA: permanent tax cuts and international adjustments
Andrew Solomon
Aharon Friedman
Andrew Solomon and Aharon Friedman (Sullivan & Cromwell) report on an
action-packed seven days in Washington.
Beard: dividends of a capital nature
Ashley Greenbank
Ashley Greenbank (Devereux Chambers) explains why form matters.
Parallel tracks
Phil Maggs
Phil Sneade
A common set of economic principles and methods underpins state aid,
competition and arm’s length analysis, write Phil Sneade and Phil Maggs
(Frontier Economics).
The Big, Beautiful Bill: one House down, one House to go
Andrew Solomon
As the Senate prepares to take up President Trump’s sweeping tax and spending
package, Andrew Solomon (Sullivan & Cromwell) considers its key provisions
and what happens next.
The clock is ticking on President Trump’s Tax Bill
Andrew Solomon
Andrew Solomon (Sullivan & Cromwell) explains why President Trump’s
plans for ‘one big, beautiful Bill’ are heading for one big, ugly negotiation.
Tariffs: a history of American protectionism
Duncan Weldon
President Trump’s approach to tariffs fits within a longer history of American
protectionism, writes economist Duncan Weldon, but was that approach ever
successful?
HMRC’s whistleblower reward scheme: what we know so far
Jack Prytherch
Jack Prytherch (Osborne Clarke) explains how the new scheme will apparently take inspiration from US and Canadian whistleblower models.
‘Amendment 24’: a tale of repeat remittances and dodgy drafting
Catrin Harrison
Dominic Lawrance
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) explain
why advisers might not need to worry about defective drafting on remittances
in the Finance Act.
Leaving the UK? How to navigate the tax maze
Tim Lynch
Tahir Ebrahim
Tim Lynch and Tahir Ebrahim (BDO) provide a back to basics guide.
International review for March 2025
Tim Sarson
Tim Sarson (KPMG) reports the growing divergence in ideology between two
of the world’s most powerful blocs, the US and the EU.
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215
EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 18 July 2025
Chancellor outlines financial services strategy
CIOT reviews transfer pricing proposals
Marriage allowance: backdating claims
Further HMRC update on VAT penalties
CASES
Read all
Abbotsford Property Group Ltd and another v Revenue Scotland
R (oao Thomas Holdings Ltd and others) v HMRC
G Stenhouse and another v HMRC
Other cases that caught our eye: 18 July 2025
B D’Angelin v HMRC
IN BRIEF
Read all
HMRC’s approach to wealthy individuals
There’s only one POEM
Discovery assessments: agents
Standish v Standish
Section 899 compromise shifts international tax landscape
MOST READ
Read all
‘Legislation Day’ date announced
G Haworth and others v HMRC
One Big Beautiful Bill Act enacted
Abbotsford Property Group Ltd and another v Revenue Scotland
Wealth taxes and fiscal reality