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International taxes
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INTERNATIONAL-TAXES
International review for January 2025
Tim Sarson
Tim Sarson (KPMG) reviews the latest developments and looks ahead at what
to expect in 2025.
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
Andrew Solomon
During Trump’s second presidential term, the spectre of tax cuts expanding the US federal budget deficit will fuel fierce debates between fiscally conservative and ‘pro-growth’ Republicans, write Donald L Korb and Andrew Solomon (Sullivan & Cromwell).
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).
HMRC v GE Financial Investments
CA holds that stapled entity not entitled to double tax relief.
International review for May 2024
Tim Sarson
Netherland’s new coalition government’s tax plans, the latest Canadian and Australian Budgets and several EU developments are included in this month’s review by Tim Sarson (KPMG).
Reform of the UK’s international tax laws: a step closer
Meenakshi Iyer
Joel Kara
Meenakshi Iyer and Joel Kara (BDO) review the outcome of the consultation on reforms to the UK’s transfer pricing, permanent establishments and diverted profits tax rules.
Skatteforvaltningen (SKAT) v Solo Capital Partners LLP (in special administration) and others
Revenue rule does not apply to Danish tax authority’s claims to recover funds.
International tax cooperation: the UN’s call for greater inclusivity and effectiveness
Sarah Blakelock
The UN is demanding a greater role in setting the global tax policy agenda,
but some countries have questioned whether this undermines the OECD/G20
Inclusive Framework discussions. Sarah Blakelock reports.
GE Financial, treaty residence, and the meaning of ‘business’
Kyle Rainsford
Kyle Rainsford (Travers Smith) examines the ramifications of the Upper Tribunal’s decision.
Tax and the City review for January 2022
Mike Lane
Zoe Andrews
The consultation on hedging risks for future share transactions and the FTT
decision in
Hargreaves
are some of the recent developments reviewed by
Mike Lane and Zoe Andrews (Slaughter and May).
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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
Broad opposition to proposed ‘reckless statements’ tax offence
GfC7 points to disclosure facility for late TP corrections
Options explored for simplifying offshore anti-avoidance rules
CIOT calls for urgent changes on IHT on pensions
Normal minimum pension age protection consultation
CASES
Read all
HMRC v G Quillan
Perenco UK Ltd v HMRC
HMRC v C Candy
Property 118 Ltd and another v HMRC
Ten cases shaping tax practice in 2026
IN BRIEF
Read all
The end of offshore execution on secondary transactions
Tax adviser registration: deferral for investment managers
When is a trustee not a trustee?
Funding the business
HMRC’s annual report for 2025/26
MOST READ
Read all
Tax Journal thanks its July 2026 authors
Property 118 Ltd and another v HMRC
Perenco UK Ltd v HMRC
When is a trustee not a trustee?
The end of offshore execution on secondary transactions