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OECD
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
Andrew Solomon
Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.
European Commission v Ireland and others
ECJ sets aside General Court’s State Aid judgment.
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
Unbridgeable divides? Recent developments do not bode well for a successful outcome to the process of reforming the international tax architecture, writes Philip Baker KC OBE (Field Court Tax Chambers).
Hybrids and dual inclusion income: are we there yet?
Richard Milnes
Fehzaan Ismail
Richard Milnes and Fehzaan Ismail (EY) assess the concept of dual inclusion
income under the UK hybrid provisions following a prolonged period of
iterative change.
International review for June 2024
Tim Sarson
Your monthly review of latest developments, by Tim Sarson (KPMG).
International review for February 2024
Tim Sarson
Tim Sarson (KPMG) reports on recent developments that matter from around the globe, in a rare month of respite from BEPS 2.0.
Tax and the City review for February 2024
Zoe Andrews
Mike Lane
The Court of Appeal’s decision in
Dolphin Drilling
and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
International review for January 2024
Tim Sarson
Tim Sarson (KPMG) reports on a flurry of activity across the international tax world and looks ahead at what to expect in 2024.
International review for October 2023
Tim Sarson
The international tax world is still dominated by BEPS 2.0 developments,
reports Tim Sarson (KPMG). This article includes an update on the national
implementation of Pillar Two.
Multinational top-up tax: an overview
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.
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EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
Scottish and Welsh Budget announcements
Lineker case settled
Anglesey Freeport: special tax sites designated
New overlap relief calculator
Additional dwelling supplement increased
CASES
Read all
C Hoyle and others v HMRC
Other cases that caught our eye: 13 December 2024
Five key cases of 2024
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
IN BRIEF
Read all
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
Read all
Stage One Creative Services Ltd v HMRC
A third route to exit: tax consequences of continuation fund transactions
Consultation tracker
Other cases that caught our eye: 6 December 2024
R Grint v HMRC