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INTRA-GROUP


Matthew Hodkin (Norton Rose Fulbright) considers some enlightening detail on a new proposal to introduce a wider exemption than first contemplated by the consultation process.

With the UK’s continuing attractiveness as a holding company tax jurisdiction, Jonathan Cooklin and Dominic Foulkes (Davis Polk) consider the scope of technical UK tax issues that have a direct bearing on the drafting of merger agreements and related documents which implement these transactions.
 

Dominic Robertson and Isabel Taylor (Slaughter and May) consider the Apple state aid decision and its impact on other businesses.

Heather Self (Pinsent Masons) examines the First-tier Tribunal case of Stagecoach, the latest case involving a complex intra-group financing scheme.

Jeanette Zaman (Slaughter and May) considers the draft legislation on hybrid mismatch arrangements and discusses their application to commercial transactions and the potential significance of the imported mismatch rules.

Chris Morgan (KPMG) provides your monthly round-up of tax developments in the international arena.

Martin Zetter provides guidance on the likely changes to the new transfer pricing regime.

Howard Murray and Sara Stewart take a look at the main tax issues as well as any other particular issues arising from pre-sale hive-downs and debt reorganisations.

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