INTERNATIONAL TAXES

This month’s review by Tim Sarson (KPMG) includes the latest batch of OECD BEPS releases and Pillar Two implementation updates from around the world.

The Upper Tribunal has, for the first time, considered the meaning of ‘exceptional circumstances’ in the context of statutory residence – and it has set the bar extremely high, write Robert Waterson and Liam McKay (RPC).

Martin Shah (Simmons & Simmons) reviews HMRC’s latest guidance on whether employees of overseas entities working temporarily in the UK give rise to a UK permanent establishment.

Bezhan Salehy and Deep Shah (Macfarlanes) review the government’s extensive package of proposals that touch most areas of the UK’s transfer pricing, permanent establishment and diverted profits tax legislation. 

This month’s update from Tim Sarson (KPMG).

Kyle Rainsford (Travers Smith) examines the ramifications of the Upper Tribunal’s decision.

The Upper Tribunal in Hargreaves effectively seeks to import the Indofood concept of beneficial entitlement into domestic law. Dominic Robertson (Slaughter and May) examines the practical uncertainties this creates and questions whether the decision was correctly decided.

Ceinwen Rees and George Apps (Macfarlanes) compare the UK’s carried interest regime to European models.

Pillar Two is gathering further momentum with announcements this month from nine territories, reports Tim Sarson (KPMG).