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Overseas subsidiary
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Overseas subsidiary
OVERSEAS-SUBSIDIARY
The VAT review for May 2022
Gary Barnett
Bryn Reynolds
This month’s update by Bryn Reynolds and Gary Barnett (Simmons & Simmons) covers the CJEU ruling on fixed establishments.
A tale of two companies in two cities: the CJEU’s ruling on fixed establishment in Berlin Chemie
Karen Killington
Karen Killington (KPMG) considers the impact of a recent case where the CJEU held that a subsidiary was not a fixed establishment.
The FII group litigation: the end of the beginning or the beginning of the end?
Cristiana Bulbuc
Lee Ellis
The Supreme Court has handed down its third judgment in the long-running
FII GLO
case. Lee Ellis and Cristiana Bulbuc (Stewarts) consider how we got here and what this means for taxpayers with unresolved issues concerning overseas dividend taxation.
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.
UK SMEs expanding overseas through a local subsidiary
Daniel Sladen
Adam Kefford
What are the key tax issues for a UK SME establishing an overseas subsidiary? Adam Kefford and Daniel Sladen (PKF-Francis Clark) report.
EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 17 October 2025
Reeves should ‘grasp the nettle’ on tax reform, says IFS
HMRC raise game on football clubs
Conservatives would scrap SDLT, says Badenoch
Tax treatment of cryptoasset exchange traded notes
CASES
Read all
Mainpay Ltd v HMRC
Dialog Semiconductor Ltd v HMRC
Hippodrome Casino Ltd v HMRC
Other cases that caught our eye: 17 October 2025
GW Martin & Co Ltd and another v HMRC
IN BRIEF
Read all
Taking cover
More on s 455
HMRC’s technical note on RIFs
HMRC’s new NIC guidance on internationally mobile employees
The tax Budget cycle
MOST READ
Read all
Isle of Wight NHS Trust v HMRC
GW Martin & Co Ltd and another v HMRC
HMRC manual changes: 10 October 2025
No escape: the new IHT tax rules for pensions
Other cases that caught our eye: 10 October 2025