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Multinationals
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Multinationals
MULTINATIONALS
The war on holding companies and the return of withholding taxes
Gregory Price
Sarah Ling
BEPS 2.0 and ATAD 3 represent the latest challenge to the tax status of holding companies, renewing focus on issues of substance and withholding taxes, write Gregory Price and Sarah Ling (Macfarlanes).
Does the international agreement on the OECD pillars mark the end of trade wars on digital taxes?
Lorand Bartels
Brin Rajathurai
The recent international agreement on the OECD’s two-pillar approach is intended to take unilateral digital tax measures off the table and put an end to these trade wars. But that does not necessarily mean there is no further role for trade law in this area, write Brin Rajathurai and Lorand Bartels (Freshfields Bruckhaus Deringer).
The G7 tax deal
Lucy Urwin
Rhiannon Kinghall Were
Rhiannon Kinghall Were and Lucy Urwin (Macfarlanes) consider what the
agreement means for the international taxation of multinationals.
Contentious tax: quarterly review
Constantine Christofi
Adam Craggs
Recent trends in the contentious tax world, by Adam Craggs and
Constantine Christofi (RPC).
Diverted profits investigations update
Jack Prytherch
Jack Prytherch (Bird & Bird) discusses what HMRC will look for in an investigation and the steps MNEs can take to protect themselves.
Transfer pricing implications of Covid-19
Paul Daly
Ken Almand
Changes in transfer pricing policies may be required as a result of the impact
of Covid-19, as Ken Almand and Paul Daly (BDO) explain.
Transfer pricing guide to cash pooling arrangements
John W. Lamszus
Daniel J. Pugh
Selena Schneider
Selena Schneider, John W. Lamszus and Daniel J. Pugh (Crowe) provide a guide to this common treasury management tool used by multinationals to efficiently manage cash and reduce process and transaction costs.
Guarantees revisited
Jenny Doak
Stuart Pibworth
Jenny Doak and Stuart Pibworth (Weil, Gotshal & Manges) revisit some of the key UK corporation and withholding tax considerations to consider on guarantees of financial obligations.
Short term business visitors
Karen McGrory
Karen McGrory (BDO) answers a query on the tax issues facing large multinationals when its employees travel internationally within the group.
Country by country reporting: practical issues
Julie Hughff
Andy Baillie
It is a year since the BEPS Action 13 final report was published. Julie Hughff and Andy Baillie (KPMG) examine the practical issues facing multinational groups.
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
Read all
Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
Read all
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
MOST READ
Read all
TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime