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Pillar two
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Pillar two
PILLAR-TWO
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.
FA 2025 review: Pillar Two: three things to note
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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of
8
EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
Tax Update 2026: government publishes simplification and compliance package
HMRC asked to clarify CIS treatment of development finance
HMRC Transfer Pricing and Profit Diversion Compliance Facility
ICTS consultation
UK-India Double Contributions Convention arrangements extended
CASES
Read all
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
Other cases that caught our eye: 26 June 2026
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Solving the LLC double taxation problem
Consultation tracker
Foreign PE exemption becoming mandatory
HMRC v GCH Corporation Ltd and others
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’