Nick Farmer and Steve Hoare recap the rules in determining whether an overseas establishment is a PE, and the implications.
Five leading tax professionals, including HMRC's Judith Knott, took part in a roundtable discussion on UK tax competitiveness. Much of the discussion, chaired by John Overs, concerned CFC reform and the potential ‘gateway’ test to filter cases out of the regime.
The Court of Appeal has handed down the latest judgment in the M&S group relief case. Alison Last assesses the impact of the decision.
Robert Langston outlines how commissionaire structures operate and the resulting tax risks following the Dell and Zimmer cases.
Helen Lethaby reviews the latest developments, including anti-avoidance concerning manufactured overseas dividends.
Robert Gaut and Sarah Gabbai provide a case study setting out the tax issues for a US manufacturing group which migrates its non-US operations to the UK
The United Kingdom would ‘easily’ take Switzerland’s place at number one in the Financial Secrecy Index if the ‘British network of secrecy jurisdictions’ were considered, according to an influential campaign group.
Ninety-eight of the 100 biggest groups listed on the London stock exchange use tax havens, according to the charity ActionAid, showing ‘just how embedded the use of tax havens is in the structures of nearly all Britain’s biggest companies’.