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INTERNATIONAL TAXES
International review for November 2024
Tim Sarson
The tax policies of President-elect Trump and the new European Commission are among the recent developments reviewed by Tim Sarson (KPMG).
FINs: a licence to fish?
David Haworth
Rose Swaffield
Financial institution notices represent a greater power for HMRC, but this does not mean that tax managers’ hands are tied, write David Haworth and Rose Swaffield (Freshfields).
Non-doms post-Budget: where are we now?
Lynnette Bober
Helen McGhee
Helen McGhee and Lynnette Bober (Joseph Hage Aaronson) provide an
overview of the new rules and highlight some key points to watch.
Derivatives, repos and stock loans: an overview
Tamar Ruiz
Matthew Mortimer
Matthew Mortimer and Tamar Ruiz (Mayer Brown) provide an overview
of the tax treatment of derivatives, repo and stock loan transactions for
UK companies.
International review for October 2024
Tim Sarson
The proposed US regulations on Corporate Alternative Minimum Tax, an
important CJEU decision on state aid and the Irish Budget are among the
recent developments reviewed by Tim Sarson (KPMG).
Ten questions on the Apple judgment
Amaury de Galbert
Dominic Robertson
Does the CJEU’s judgment in
Apple
signify a major shift in tax State aid
cases? Or is
Apple
likely to be a one-off? Amaury de Galbert and Dominic
Robertson (Slaughter and May) investigate.
International review for September 2024
Tim Sarson
The Irish Apple state aid case and the US electoral candidates respective tax
policies are among the recent developments reviewed by Tim Sarson (KPMG).
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
Andrew Solomon
Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
Unbridgeable divides? Recent developments do not bode well for a successful outcome to the process of reforming the international tax architecture, writes Philip Baker KC OBE (Field Court Tax Chambers).
The Court of Appeal favours form over function in GE Financial
Kyle Rainsford
In
GE Financial Investments
, the Upper Tribunal favoured the functional
interpretation while the Court of Appeal favoured the territorial, writes
Kyle Rainsford (Addleshaw Goddard).
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