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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
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
Tax Journal thanks its July 2026 authors
GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
Read all
Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
Read all
Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
MOST READ
Read all
The VAT treatment of prize draws
The new duty to correct tax return errors
Loan charge settlement scheme: regulations and guidance published
Requirements for forthcoming pensions IHT changes
One minute with... Tim Gummer