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IN BRIEF

Views on recent developments in tax.

Changes of government have often led to less substantial divergences in tax policy than one might think.
What does this mean for employers?
A recent Upper Tribunal decision gives cause for concern.
If the CEST tool is completed and a contrary view is taken, HMRC must be notified.
There is a potential additional hurdle to clear if interest on intra-group debt is to be tax deductible in the UK.
Too quick off the mark.
Is full implementation of the Pillar Two rules by the US now looking less likely?
The Upper Tribunal confirms that daily penalties for failure to make ATED returns can be charged retrospectively.
Which trusts are now required to register, what are the deadlines and what are they required to disclose?

Despite yet another setback in the adoption of the EU pillar two directive, there is no rest in the horizon for EU’s tax policies. As the Commission and the Council reflect on ways forward on minimum taxation, there is much more to look forward to: renewed prospect of a EU digital tax initiative, possible initiative to circumvent Council’s unanimity rule on tax policies, a proposal to tackle tax enablers, exchanging information on crypto-assets, and adapting VAT rules for the digital age.

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