MULTINATIONALS

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) review Hotel La Tour, recent developments affecting the taxation of global mobility and HMRC’s new compliance guidelines on imported hybrid mismatches.

Philip Baker KC

In a follow-up article to his piece on the prospects for international tax reform, Philip Baker KC (Field Court Tax Chambers) gives a personal view of what he sees as some of the critical tax issues that should drive international reform – and the potential solutions.

Mark Saunderson Paul McColgan Jason Groves

Jason Groves, Mark Saunderson and Paul McColgan (Deloitte) set out some recommendations for UK professionals advising businesses with large US operations.

Robert Langston

Robert Langston (Saffery) provides a practical case study on the operation of the corporate interest restriction where related party guarantees and withholding tax issues are involved.

Tamar Ruiz

Matthew Mortimer

The multinational top-up tax regime appears to be endlessly complicated. Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine ten aspects of the regime, including a ten-step process to navigating the rules.

Mike Lane

Zoe Andrews

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the Court of Appeal decisions in Royal Bank of Canada and Civic Environmental Systems and the consultation on transfer pricing, DPT and permanent establishment.

Chris Sanger

Jack Gifford

The UK’s approach may require taxpayers to take a leap of faith that the final legislation will align with the GloBE rules, write Chris Sanger and Jack Gifford (EY).

Elena Rowlands Jessica Kemp Laura Hodgson

Laura Hodgson, Elena Rowlands and Jessica Kemp (Travers Smith) analyse the UK’s draft multinational top-up tax legislation and consider what developments are still to come.

Brin Rajathurai

May Smith

Brin Rajathurai and May Smith (Freshfields Bruckhaus Deringer) explain how pillar two will have an uneven impact on the attractiveness of different target companies and potentially favour certain types of bidders over others.

Mark Bevington

Mark Bevington (ADE Tax) highlights the ‘traps’ on the operation of the pillar two model rules which might generate a tax charge when none was expected.

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