INTERNATIONAL-TAXES

Zoe Andrews

Mike Lane

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) looks at the decisions in Beard and Rettig, as well as HMRC’s revised guidance on unallowable purpose.

Tim Sarson

US developments dominate the headlines in this month’s update by Tim Sarson (KPMG).

Tim Sarson

Key policy developments in the US and an AG opinion on VAT on transfer pricing are among the topics examined this month by Tim Sarson (KPMG).

Payments to an Ireland government agency were not deductible under the loan relationship rules

DTT anti-abuse provision did not deny UK withholding exemption

Court of Appeal upholds UT decision disallowing amortisation debits

Burden of proof and civil penalties: The Court of Appeal in HMRC v Sintra Global Inc and another [2025] EWCA Civ 1661 (18 December 2025) decided in favour of HMRC, holding that the UT had made various errors of law, in particular, by...

Alyssa Haggarty

Claire Weeks

Alyssa Haggarty and Claire Weeks (Maurice Turnor Gardner) consider the status of the so-called ‘revenue rule’ and the options available to HMRC to seek assistance in the collection of tax abroad.

Expat’s pension escapes tax as link to employment unbroken by fund transfer

Tim Sarson

This month’s review by Tim Sarson (KPMG) includes insight on the latest developments from the US Administration and the European Community.

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