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Pillar two
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Pillar two
PILLAR-TWO
Pillar Two: local variations, global complications
Lisa Shipley
Alison Lobb
Alison Lobb and Lisa Shipley (Deloitte) examine how national variations in Pillar Two, including local accounting standards and safe harbour restrictions, increase complexity and compliance costs for multinational groups.
International review for June 2026
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).
Tax and the City for February 2026
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.
The Pillar Two Side-by-Side package: how UK groups should approach compliance
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.
International review for January 2026
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.
The OECD’s Pillar Two side-by-side package
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.
International tax reform: what are the critical issues?
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.
Budget 2025: the view from the 100 Group Tax Committee
Dominic Mathon
Dominic Mathon (100 Group Tax Committee) reiterates the urgent need for
tax reform to encourage UK investment and boost economic growth.
Beyond the billions: how the 100 Group’s tax contribution reflects a broader corporate responsibility
David Gordon
The discussion about tax responsibility should go beyond the rate of tax
companies pay, writes David Gordon (100 Group Taxation Committee).
Finance Act 2025: special report
Ros Martin
A detailed report of this year’s Finance Act.
Go to page
of
9
EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
NEWS
Read all
Tax Journal authors for October
Budget capital allowances changes: mixed picture for business investment decisions
Government declines to expand land remediation relief
HMRC publish new RTI guidance for employers
ERS: annual returns after scheme closure
CASES
Read all
Abbey Group Ltd v HMRC
Strauss Phillips & Co Ltd v HMRC
Education Training Collective v HMRC
Other cases that caught our eye: 30 October 2026
ScottishPower (SCPL) Ltd and others v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
ScottishPower (SCPL) Ltd and others v HMRC
Side-by-Side: four scenarios for 2030