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Anne Powell (Bryan Cave Leighton Paisner) considers how our historic experience of tax covenants steer us to resolve new Pillar Two risks.
The thrust of HMRC’s guidance is to reject the notion that a profit split shouldn’t be used to reward risk control contributions, write Phil Roper and Charles Havisham (KPMG).
A detailed report by Lexis®+ UK Tax.
Card image Ben Jones, Deepesh Upadhyay, Benjamin Shem-Tov
Ben Jones, Deepesh Upadhyay and Benjamin Shem-Tov (Eversheds Sutherland) examine the increasing use of side fund letters in a private investment funds context and the associated most favoured nations process.
Tax, treasury and finance consultant Peter Mason sets out some ‘commandments’ for responsible tax authority engagement.

Are some corporates being too complacent and where might their current efforts be deficient, asks Jason Collins and Penny Simmons (Pinsent Masons).

HMRC has launched its enhanced business risk review pilot. Lucy Sauvage and Laura Harper (BDO) assess the proposed changes.
HMRC is revisiting the way it risk assesses businesses. Lucy Sauvage and Laura Harper (BDO) consider practical issues for those affected.

Richard Collier and Aamer Rafiq (PwC) look at the recent OECD BEPS discussion paper

Liesl Fichardt reports on findings from a recent survey examining industry views on the competitiveness of the UK tax regime, reputational risk, disputes and HMRC practices