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Two models of unilateral taxation, and Poland’s hybrid
Sandy Bhogal
Graham Crocker
In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) agreed a Two-Pillar Solution to address the tax challenges arising from the digitalisation of the economy. Pillar One of the Two-Pillar Solution contains two...
International review for July 2024
Tim Sarson
Pressure grows for a global wealth tax. This and other recent developments in
international tax are examined by Tim Sarson (KPMG).
International review for September 2023
Tim Sarson
This month’s review by Tim Sarson (KPMG) includes the latest batch of OECD BEPS releases and Pillar Two implementation updates from around the world.
The OECD’s statement on international tax reform
Sandy Bhogal
James Chandler
Sandy Bhogal and James Chandler (Gibson, Dunn & Crutcher) review the proposed reforms allocating corporate profits to customer-heavy jurisdictions and imposing a global minimum tax rate.
The G7 tax deal
Rhiannon Kinghall Were
Lucy Urwin
Rhiannon Kinghall Were and Lucy Urwin (Macfarlanes) consider what the
agreement means for the international taxation of multinationals.
Digitalisation: where are we headed?
Robert O'Hare
Jefferson VanderWolk
Robert O’Hare and Jefferson VanderWolk (Squire Patton Boggs) discuss the
current state of play and what needs to be resolved.
Self’s assessment: a digital trade war?
Heather Self
In our continuing series, Heather Self examines tax issues reported in the national media. This week, following news that the US has suggested halting multinational discussions on the OECD’s ‘pillar one’ digital tax proposals, are we heading for a tax trade war?
UK tax pitfalls of the foreign company
Laura Hoyland
Elizabeth Emerson
Laura Hoyland and Elizabeth Emerson (White & Case) explain the various bear-traps for a foreign company proposing to do business in the UK.
The UK’s digital services tax: what’s changed
Michael Alliston
Judy Harrison
Michael Alliston and Judy Harrison (Norton Rose Fulbright) consider what's new in HMRC's guidance and how the Finance Bill legislation has changed since the earlier draft.
What’s in store: the Conservative Party’s tax pledges
Rhiannon Kinghall Were
Rhiannon Kinghall Were (Macfarlanes) reviews the tax pledges of the new government.
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EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
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
NEWS
Read all
Tax Journal authors for October
Budget capital allowances changes: mixed picture for business investment decisions
Government declines to expand land remediation relief
HMRC publish new RTI guidance for employers
ERS: annual returns after scheme closure
CASES
Read all
Abbey Group Ltd v HMRC
Strauss Phillips & Co Ltd v HMRC
Education Training Collective v HMRC
Other cases that caught our eye: 30 October 2026
ScottishPower (SCPL) Ltd and others v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
ScottishPower (SCPL) Ltd and others v HMRC
Side-by-Side: four scenarios for 2030