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INTERNATIONAL TAXES


The OECD’s programme of work on tax and digitalisation is energising debate about the future of international tax, reports Julian Feiner (Clifford Chance).
Tim Sarson (KPMG) reviews some of the interesting developments that unfolded over the past year in the international tax arena.
Experts at Freshfields Bruckhaus Deringer examine the OECD's pillar two proposals which could have a fundamental impact on the way all multinationals are taxed.
The judgments of the General Court in the Starbucks and Fiat cases give important guidance on some of the fundamental questions concerning the application of EU state aid rules to individual tax rulings, write Wiebe Dijkstra and Arjan Kleinhout (De Brauw Blackstone Westbroek).
Robert Langston (Saffery Champness) considers new HMRC guidance that provides some clarification, although there are still areas that are left open. 
Gary Richards and Robert Hartley (Mishcon de Reya) focus on how OECD’s public consultation document on the ‘unified approach’ under pillar one sheds light on the future scope of the arm’s length principle.
The UK DST in its current form may well breach the UK’s obligations under double tax treaties, international trade law, or both, write Rupert Shiers and Jonathan T Stoel (Hogan Lovells).
Tim Sarson (KPMG) assesses the latest developments that matter in the international tax arena.
What are the tax and customs implications of new Withdrawal Agreement and non-binding post-Brexit Political Declaration? Richard Asquith (Avalara) reviews. 
Brin Rajathurai and Murray Clayson (Freshfields Bruckhaus Deringer) examine the proposals on ‘pillar one’ of an international solution to the taxation of multinational enterprises in the digital economy by 2020.
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