ANALYSIS

Cutting edge analysis on tax issues.

Simon Whitehead and Peter Stewart (Joseph Hage Aaronson) review the recent decision in Six Continents, which considers what foreign profits should receive credit at the foreign nominal rate following an earlier ruling of the CJEU in the FII group litigation.

Paul Howard

Paul Howard (Gabelle) provides this month’s update examining the most significant recent tax developments affecting SMEs.

Allan Cinnamon

Allan Cinnamon (Cintax the Word Ltd) provides a quarterly update on recent tax treaty developments.

Stephen Quest

Stephen Quest (European Commission) explains how the Commission is pursuing a comprehensive agenda of reform to make corporate taxation in Europe fairer, more effective and more growth friendly.

Helen Miller

Helen Miller (Institute for Fiscal Studies) asks, with such a wide divergence of views on what counts as avoidance, should we ever expect to reach agreement on whether the international tax system is fixed?

Maya Forstater

The art of estimating the scale of tax avoidance, examined by researcher Maya Forstater.

Mark Middleditch

Mark Middleditch (Allen & Overy) provides this month’s update on developments affecting the City.

Gary Barnett

Gary Barnett (Simmons & Simmons) reports that further questions have been referred to the CJEU on the scope of the VAT exemption for transactions concerning payments and transfers in the context of payment administration services provided to a debtor.

Raymond Hill

Richard Iferenta

After formal Brexit, it is likely that the decisions of the CJEU on the VAT directives will remain of persuasive authority in interpreting the UK VAT Act, write Richard Iferenta (KPMG) and Raymond Hill (Monckton Chambers).

Conor Quigley

Conor Quigley QC (Serle Court) argues that the Commission’s approach to state aid seems to misunderstand the whole purpose of tax rulings concerning transfer pricing.

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