Clara Boyd, Lauren Redhead and Emily Burke (DLA Piper) review the changing contentious tax landscape, including the courts continuing efforts on improving procedural certainty.
James Shorland (Alvarez and Marsal) explores some of the unintended UK tax consequences of master holdco structures on portfolio companies of private equity funds.
Mike Lane and Zoe Andrews (Slaughter and May) examine recent decisions of interest and the latest transfer pricing and diverted profits tax statistics.
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).
Tom Gilliver (Slaughter and May) considers the procedural challenges that arise from the interaction between the transfer pricing and diverted profits tax rules.