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Double taxation
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Double taxation
DOUBLE-TAXATION
International review for April 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
Finance Bill 2021: hybrid mismatch rules version 2.0
Claudine Fox
Nick Evans
The UK hybrid rules impose double taxation as currently enacted, explain
Nick Evans and Claudine Fox (Baker McKenzie). Changes will be made, but
do they go far enough?
International holding structures: are they structurally sound?
Aaron Mehta
Creina Kane
Jenni Bullivant
Jenni Bullivant, Creina Kane and Aaron Mehta (PwC) reflect on the host of international tax issues and complexities associated with international holding structures as a consequence of the continually changing external landscape.
The three Ps of pillar one
Mark Bevington
Mark Bevington (ADE Tax) discusses the policy, politics and practicalities of
the pillar one proposals.
AXA v Genworth: gross misunderstandings?
Helen Coward
Helen Coward (Charles Russell Speechlys) reviews a recent High Court case
on the meaning of a gross-up clause in a share purchase agreement.
Tax and the City review for September 2020
Mike Lane
Zoe Andrews
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
Davies: transfer of assets abroad
The tax avoidance anomaly.
Tax and the City review for June 2020
Mike Lane
Zoe Andrews
Deeming rules, debits, partnerships and pension funds all feature within this month's update, by experts at Slaughter and May.
Fowler: employment or treaty deemed trade?
Nigel Doran
Nigel Doran (Macfarlanes) examines the recent Supreme Court decision and its ramifications.
The disguised remuneration regime unpacked
Karen Cooper
Karen Cooper (Cooper Cavendish) sets out the rules, tax treatment and the impact of legislation on EBTs and remuneration planning.
Go to page
of
5
EDITOR'S PICK
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
1 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
2 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
3 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
4 /7
The new Securities Transfer Tax: business as usual?
Georgina West
5 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
6 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
7 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
NEWS
Read all
OECD issues Pillar Two review framework and revised GIR
VAT refund policy change for non-UK members of VAT groups
VAT on fund management services: new HMRC guidelines
Temporary zero rate for domestic electricity
CBAM admin regulations published
CASES
Read all
J Scheckter v HMRC
Luxurico Ltd v HMRC
C Sagar v HMRC
Other cases that caught our eye: 18 September 2026
The Executors of Hunt and others v HMRC
IN BRIEF
Read all
TOGCs and leases
Principal or agent?
HMRC get more bang for their buck
Sanctionable conduct
The end of offshore execution on secondary transactions
MOST READ
Read all
Grand Smile Design Ltd v HMRC
Raising standards without regulating the profession
Consultation tracker
The Executors of Hunt and others v HMRC
HMRC manual changes: 4 September 2026