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Tax and the City review for June 2021

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The Ramsay principles of statutory construction are applied by the Court of Appeal in Khan and the Supreme Court in Hurstwood. The Court of Appeal in Dodika concludes that the notice of a tax covenant claim does contain sufficient detail to meet the contractual requirement and is, therefore, valid because there were not any further specific details which could usefully have been provided. The European Commission shares its latest plans to harmonise tax rates and tax rules and introduce a new digital levy across the EU but it is unclear how these proposals will sit with the new taxing right and minimum rate of tax currently being discussed globally to reform the international corporate tax framework.

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