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ANALYSIS

Cutting edge analysis on tax issues.

HMRC’s Large Business Director, Judith Knott, talks about the department’s approach to dealing with this sector.

On 22 October, HM Treasury and HMRC published a consultation document requesting views on proposed changes to the UK patent box regime to be legislated in next year’s Finance Bill. Jonathan Bridges and Carol Johnson (KPMG) explain why the UK rules are being changed and how the changes will affect taxpayers.
 
Heather Self and Caroline Ramsay (Pinsent Masons) delve into the EC’s decisions that Starbucks and Fiat tax rulings were unlawful state aid and what this is likely to mean for other multinationals operating in the EU.
 

Lee Squires and Fiona Bantock (Hogan Lovells) look at recent developments, including: the decisions in Riskstop Consulting and Hedqvist; VAT on pension fund management costs; and the EC consultation on cross-border e-commerce.

Cutting tax credits should have been meat and drink to George Osborne; he did it in the last parliament. David Smith asks why he got into so much trouble this time.
 

The Summer Finance Bill 2015 includes a new measure subjecting restitution interest to a charge to corporation tax at a rate of 45%. Paul Farmer and Jivaan Bennett (Joseph Hage Aaronson) explain the background and key elements of the proposed legislation.

BEPS marks a turning point in international tax, but the work is not over yet.
 

Jill Gatehouse and Susanna Brain (Freshfields Bruckhaus Deringer) provide an expert practitioner review of the OECD’s initiative to tackle base erosion and profit shifting.

Tom Scott (McDermott Will & Emery) looks at hybrid arrangements and the effect of the OECD proposals.

Charles Yorke (Allen & Overy) reviews Action 4 of the BEPS report.

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