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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
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
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
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Tax Journal thanks its July 2026 authors
GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
Read all
Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
Read all
Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
MOST READ
Read all
The VAT treatment of prize draws
Loan charge settlement scheme: regulations and guidance published
The new duty to correct tax return errors
Requirements for forthcoming pensions IHT changes
Consultation tracker