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Pillar two
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Pillar two
PILLAR-TWO
Tax and the City review for November 2022
Mike Lane
Zoe Andrews
This month’s round-up, by Mike Lane and Zoe Andrews (Slaughter and May).
International review for September 2022
Tim Sarson
Tim Sarson (KPMG) reviews the international landscape, including renewed impetus to implement Pillar Two and the latest US tax developments.
UK implementation of Pillar Two: where are we now?
Elena Rowlands
Jessica Kemp
Laura Hodgson
Laura Hodgson, Elena Rowlands and Jessica Kemp (Travers Smith) analyse the UK’s draft multinational top-up tax legislation and consider what developments are still to come.
Pillar two and the future of tax incentives
Bezhan Salehy
Bezhan Salehy (Macfarlanes) considers how countries may maintain their tax competitive standing after the implementation of pillar two.
The impact of the OECD’s pillar two on international M&A
Brin Rajathurai
May Smith
Brin Rajathurai and May Smith (Freshfields Bruckhaus Deringer) explain how pillar two will have an uneven impact on the attractiveness of different target companies and potentially favour certain types of bidders over others.
International review for June 2022
Tim Sarson
Delay and a lack of political consensus on BEPS feature in this month’s review
by Tim Sarson (KPMG).
International review for May 2022
Tim Sarson
The latest on BEPS, tax transparency and transfer pricing, reviewed by Tim Sarson (KPMG).
How pillar two attacks multinationals’ high tax subsidiaries
Mark Bevington
Mark Bevington (ADE Tax) highlights the ‘traps’ on the operation of the pillar two model rules which might generate a tax charge when none was expected.
International review for March 2022
Tim Sarson
OECD commentary on the pillar two model rules and the responses to the pillar one public consultations are among the recent developments examined by Tim Sarson (KPMG).
International review for January 2022
Tim Sarson
Tim Sarson (KPMG) reports on a busy start to what promises to be an eventful year for the international tax world.
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8
EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
HMRC manual changes: 9 January 2026
Agreement reached on Pillar Two ‘side-by-side’ package
Late change lifts BPR/APR cap
New guidelines on imported hybrid mismatch rules
VAT treatment of supplies of temporary medical staff
CASES
Read all
HMRC v Hotel La Tour Ltd
County Insurance Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
R Sehgal v HMRC
Other cases that caught our eye: 9 January 2026
IN BRIEF
Read all
TSI Instruments and import VAT recovery
Voluntary returns and impossible penalties
Budget 2025 changes to the share exchanges and reorganisation rules
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
MOST READ
Read all
HMRC manual changes: 12 December 2025
Agreement reached on Pillar Two ‘side-by-side’ package
Cases of 2025
The Tower One St George Wharf Ltd v HMRC
Consultation tracker