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It is clear that the government feels the need to ‘do something’. However it is much less clear that the diverted profits tax proposals is the best thing to do as Heather Self (Pinsent Masons) explains.

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).

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Heather Self (Pinsent Masons) examines the FTT decision where a UK corporate taxpayer succeeded in an argument about loan relationships or financial instruments against HMRC.
 

It is legitimate for tax campaigners to call for reform of the tax system but it is not legitimate to criticise companies on the basis that they have claimed tax reliefs in accordance with the current rules writes Heather Self.

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.
 

Australia like the UK has announced new measures countering the diversion of profits by multinationals writes...

In this series Heather Self examines tax issues in the headlines of the national press. This week she examines the tax promises in the manifestos of the two major political parties - which are perhaps more notable for what the parties say they won’t do rather than...
A recent tribunal decision on whether the taxpayer had an unallowable purpose is likely to be of wide application as Heather Self (Blick Rothenberg) explains. But was it correctly decided?
In the first of a new series of interviews with senior HMRC figures  HMRC’s Director for Intermediaries Rob Jones speaks to Heather Self about mandatory registration adviser standards and what the department expects from the profession.

Tax Journal thanks its authors for January (click on links below to view author profiles and access article links).

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