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Overseas subsidiary
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OVERSEAS-SUBSIDIARY
The VAT review for May 2022
Bryn Reynolds
Gary Barnett
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
Daniel J. Pugh
John W. Lamszus
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
Adam Kefford
Daniel Sladen
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: 5 September 2025
Pre-Budget speculation fuels rumours of bank windfall tax and landlord NICs
Submitting RIF notifications to HMRC
HMRC guidelines on declarations of accuracy and completeness
EV charging added to advisory fuel rates
CASES
Read all
Lexgreen Services Ltd v HMRC
Elphysic Ltd and others v HMRC
W Tinkler v HMRC
Clear Pay Payroll Ltd v HMRC
Other cases that caught our eye: 5 September 2025
IN BRIEF
Read all
Closing the tax gap: HMRC’s approach to ‘legal interpretation disputes’
CenTax recommends changes to protect family farms
Soft Drinks Industry Levy credit repayments
Self’s assessment: Time for a wealth tax?
Highlights from HMRC’s 2024/25 annual report
MOST READ
Read all
First failure to prevent the facilitation of tax evasion case
T Masters v HMRC
Government mulls reforms to property taxes
Government mulls reforms to property taxes
United Carpets (Franchisor) Ltd v HMRC