OECD

HMRC’s large business director, Nicole Newbury, outlines the department’s  approach, including priority areas of focus and how it is evolving to reflect wider changes in the economy and customers’ circumstances. 

Martin Shah (Simmons & Simmons) reviews HMRC’s latest guidance on whether employees of overseas entities working temporarily in the UK give rise to a UK permanent establishment.

This month’s update from Tim Sarson (KPMG).

Brin Rajathurai, James Burton and Mitchell Fraser (Allen & Overy) review last week’s OECD announcements on the two-pillar solution.

Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.

It is full steam ahead for implementation of the global minimum tax in the UK and the EU, report Mike Lane and Zoe Andrews (Slaughter and May).

Tim Sarson (KPMG) reviews the international landscape, including renewed impetus to implement Pillar Two and the latest US tax developments.

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.

Laura Hodgson (Travers Smith) explains why the proposed new rules may require businesses to bolster the substance of their EU holding companies.

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).