ANALYSIS

Cutting edge analysis on tax issues.

FastFood is based in San Francisco and operates a takeaway delivery app. Marco is a self-employed delivery rider based in London. FastFood charges Marco acommission on every delivery Marco completes using the FastFood app. The commission is...

Kate Ison

Budget 2026 was billed as providing breathing space for businesses and families, but there was little let-up in the Governments now well-trodden focus on tax compliance and enforcement. Although many of the compliance-related...

Adam Craggs

Predictions that Budget 2026 would be a relatively pedestrian affair proved accurate, with a focus on easing cost of living pressures and few surprises. Labours manifesto commitment not to raise headline taxes, coupled with an increasingly...

Duncan Weldon

John Healeys first Budget as Chancellor was, in many ways, a low-key affair. Indeed it felt more like an old school Autumn Statement, of the kind Conservative chancellors unveiled over the course of the 2010s, than a full Budget. That is to...

Philip Baker KC

Philip Baker KC (Field Court Tax Chambers) considers why existing rules struggle to tax cross-border services effectively and proposes an alternative solution.

Lisa Shipley

Alison Lobb

Alison Lobb and Lisa Shipley (Deloitte) examine how national variations in Pillar Two, including local accounting standards and safe harbour restrictions, increase complexity and compliance costs for multinational groups.

Ian Dennis

Chris Sanger

Chris Sanger and Ian Dennis (EY) set out four possible futures for Pillar Two, exploring the competitive implications of the Side-by-Side regime and the practical choices facing heads of tax.

Giorgia Maffini

Giorgia Maffini (PwC) considers whether OECD transfer pricing reforms will deliver simplification or greater scrutiny, focusing on intra-group services, Amount B and growing differences between jurisdictions.

Sandy Bhogal

Graham Crocker

In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) agreed a Two-Pillar Solution to address the tax challenges arising from the digitalisation of the economy. Pillar One of the Two-Pillar Solution contains two...

Julius Konstantin Berling

Liesl Fichardt

Liesl Fichardt and Julius Berling (Quinn Emanuel) examine OECD, EU and UN initiatives to improve international tax dispute resolution, as well as the increasing use of domestic alternative dispute resolution.

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