James Ross (McDermott Will & Emery) responds to a reader’s different interpretation of the new hybrid rules.
Philip Hammond may have thought he was inheriting a poisoned chalice when he took over as chancellor last summer, but things have turned out better than he feared, as David Smith reports.
Dan Neidle (Clifford Chance) provides a different view on the operation of the new hybrid rules.
HMRC has published revised guidance preventing any transfer pricing discussions with taxpayers outside APAs or enquiries, write Peter Steeds & Paul Fields (KPMG).
A few things appeared in the draft Finance Bill which may raise eyebrows, writes Peter Vaines (Field Court Tax Chambers).
Whilst the UK has been a strong proponent of the BEPS recommendations generally, there are indications that the UK will not adopt all the measures designed to clamp down on the artificial avoidance of permanent establishment status. What does this mean for the future implementation of BEPS? asks Rebecca Reading (RSM UK).
The CJEU has issued its decision in Santander, and the EC has published the full non-confidential version of its decision in the Apple case. They suggest an uphill struggle for Ireland and Apple in their attempt to overturn the EC’s decision, write Caroline Ramsay & Heather Self (Pinsent Masons).