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International taxes
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INTERNATIONAL TAXES
End of year musings on corporate tax
Jenny Doak
Jenny Doak (Paul Hastings) contrasts a year of relative domestic stability with
international upheaval.
Budget 2025: HMRC’s whistleblower scheme launches with limited detail
Craig Kirkham-Wilson
The Autumn Budget has confirmed the introduction of a new scheme to reward informants who help HMRC recover tax that has been avoided or evaded. Announced by James Murray MP in March 2025, the scheme is designed to incentivise...
Budget 2025: DST heading for a Clash: should I stay, or should I go now?
Patrick O'Gara
HM Treasury has presented its long-awaited report to Parliament of its mandated review of the digital services tax, the controversial two per cent levy on revenues earned from the provision of social media, search engine and online marketplace...
Budget 2025: International private client tax issues
Helen McGhee
Lynnette Bober
There were several measures introduced by the 2025 Budget that will be of particular interest to HNW internationally mobile individuals, and I highlight a few of these below. 5m IHT cap for pre-October 2024 EPTs: There will be a 5m cap...
Budget 2025: Complaints old and new: what the Budget really tells us about tax
David Milne KC
There will be the usual complaints about the tax burden on working people, but it is very modest compared with the 1960s and 1970s, when the top rate of income tax was still 98%, imposed to pay the USA for the monies lent to us for WW2. There will...
International tax reform: what are the critical issues?
Philip Baker KC
In a follow-up article to his piece on the prospects for international tax
reform, Philip Baker KC (Field Court Tax Chambers) gives a personal view of
what he sees as some of the critical tax issues that should drive international
reform – and the potential solutions.
International review for October 2025
Tim Sarson
This month’s update by Tim Sarson (KPMG) has a distinctly European
flavour, and illustrates how politics – and not always domestic politics –
influences tax policy.
OBBBA: one big beautiful guide for non-US tax professionals
Paul McColgan
Jason Groves
Mark Saunderson
Jason Groves, Mark Saunderson and Paul McColgan (Deloitte) set out
some recommendations for UK professionals advising businesses with large
US operations.
Across the pond: comparing US and UK M&A tax protections
Richard Liu
Simon Skinner
With the increasing prevalence of US buyers of UK businesses, and consequently more ‘US-style’ deals than ever, Simon Skinner and Richard Liu (Latham & Watkins) de-mystify what this means and explain the key differences in US market practice for M&A tax protections.
How to interpret double tax treaties
Kyle Rainsford
Following a recent flurry of cases, Kyle Rainsford (Addleshaw Goddard)
revisits the basic principles of interpreting tax treaties in the UK.
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EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
NEWS
Read all
Tax Journal authors for October
Budget capital allowances changes: mixed picture for business investment decisions
Government declines to expand land remediation relief
HMRC publish new RTI guidance for employers
ERS: annual returns after scheme closure
CASES
Read all
Abbey Group Ltd v HMRC
Strauss Phillips & Co Ltd v HMRC
Education Training Collective v HMRC
Other cases that caught our eye: 30 October 2026
ScottishPower (SCPL) Ltd and others v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
ScottishPower (SCPL) Ltd and others v HMRC
Side-by-Side: four scenarios for 2030