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Pillar two
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Pillar two
PILLAR-TWO
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...
International review for January 2025
Tim Sarson
Tim Sarson (KPMG) reviews the latest developments and looks ahead at what
to expect in 2025.
Go to page
of
8
EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
Consultation launched on extending UTT regime
Finance Bill completes parliamentary stages
Regulations set 2026/27 NIC rates and extend veterans relief
Further NIC re-rating provisions for 2026/27
Voluntary NIC window for those abroad closes soon
CASES
Read all
Muller UK and Ireland Group LLP and others v HMRC
Countrywide Partners Ltd v HMRC
S Kamal v Tax Policy Associates Ltd and another
Other cases that caught our eye: 20 March 2026
CooperVision Lens Care Ltd v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
CooperVision Lens Care Ltd v HMRC
Consultation tracker
Transactions in Securities counteraction notices
Capital by name, income in nature: the Upper Tribunal’s decision in BCG
Finance Bill 2026 progress