PILLAR-TWO

Tim Sarson

Pillar Two filing, an AG opinion on the EU anti-abuse rule and Budget measures in Australia and New Zealand are among the developments in this month’s review, by Tim Sarson (KPMG).

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) reflect on the judgment in Watts on purposive construction, Ripe on intangible fixed assets, the new Pillar Two safe harbours, and HMRC’s new transfer pricing guidelines.

Jack Gifford

Jack Gifford (EY) shares practical views on two of the most pressing Pillar Two issues for UK multinationals: the newly released Side-by-Side package and the fast approaching initial GIR filing deadline.

Tim Sarson

This month, Tim Sarson (KPMG) reviews the Pillar Two Side-by-Side package, the Japanese tax proposals and the French Budget, and considers what to expect in the coming year.

Lisa Shipley Alison Lobb Ed Wright

Alison Lobb, Lisa Shipley and Ed Wright (Deloitte) outline the Inclusive Framework’s much-awaited ‘side-by-side’ package.

Philip Baker KC

In a follow-up article to his piece on the prospects for international tax reform, Philip Baker KC (Field Court Tax Chambers) gives a personal view of what he sees as some of the critical tax issues that should drive international reform – and the potential solutions.

Dominic Mathon

Dominic Mathon (100 Group Tax Committee) reiterates the urgent need for tax reform to encourage UK investment and boost economic growth.

David Gordon

The discussion about tax responsibility should go beyond the rate of tax companies pay, writes David Gordon (100 Group Taxation Committee).

Ros Martin

A detailed report of this year’s Finance Act.

Bezhan Salehy

FA 2025 includes various provisions connected to the UK’s implementation of the OECD Pillar Two global minimum tax initiative. There are three main things to note: Undertaxed Profits Rule (UTPR): The main mechanism by which countries will...

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