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Pillar two
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Pillar two
PILLAR-TWO
The Trump effect: US foreign tax policy
Tanja Velling
Among the executive orders signed by President Trump is a firm rebuff of the OECD’s two-pillar solution, writes Tanja Velling (Slaughter and May).
Pillar Two one year on: what have we seen and where are we going?
Kara Heggs
Jisun Choi
Jisun Choi and Kara Heggs (Skadden, Arps, Slate, Meagher & Flom) take stock of some of the practical issues arising from Pillar Two.
Pillar Two and funds: there is no panacea
Alistair Godwin
Andrew Yeomans
Alistair Godwin and Andrew Yeomans (EY) review three areas of complexity
that present challenges to asset managers.
International review for October 2024
Tim Sarson
The proposed US regulations on Corporate Alternative Minimum Tax, an
important CJEU decision on state aid and the Irish Budget are among the
recent developments reviewed by Tim Sarson (KPMG).
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L Korb
Andrew Solomon
Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
Unbridgeable divides? Recent developments do not bode well for a successful outcome to the process of reforming the international tax architecture, writes Philip Baker KC OBE (Field Court Tax Chambers).
International review for July 2024
Tim Sarson
Pressure grows for a global wealth tax. This and other recent developments in
international tax are examined by Tim Sarson (KPMG).
International review for June 2024
Tim Sarson
Your monthly review of latest developments, by Tim Sarson (KPMG).
Pillar Two: assessing the impact on the UK FTSE 100
Lavina Hassasing
Alistair Nichol
The expected impact of the new Pillar Two regime is starting to unfold as
the first UK groups have filed their calendar year-end consolidated accounts,
write Alistair Nichol and Lavina Hassasing (Evelyn Partners).
International review for May 2024
Tim Sarson
Netherland’s new coalition government’s tax plans, the latest Canadian and Australian Budgets and several EU developments are included in this month’s review by Tim Sarson (KPMG).
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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
Tax Journal authors for March
New reporting requirements for close company payments proposed
Lords amendments to NICs Bill rejected
Call for evidence: phase out of remaining ACT regime
Call for evidence: business systems integration
CASES
Read all
HMRC v Colchester Institute Corporation
HMRC v Boehringer Ingelheim Ltd
R (oao Rokos) v HMRC
HMRC v C Brzezicki
J Hosking 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
J Hosking v HMRC
Exceptional circumstances – but which way?
Countrywide Partners Ltd v HMRC
Muller UK and Ireland Group LLP and others v HMRC
Consultation tracker