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COMPLIANCE
Unify and conquer: the OECD’s ‘unified approach’ to pillar one
Brin Rajathurai
Murray Clayson
Brin Rajathurai and Murray Clayson (Freshfields Bruckhaus Deringer) examine the proposals on ‘pillar one’ of an international solution to the taxation of multinational enterprises in the digital economy by 2020.
The corporate criminal offences: two years on
Oliver Pumfrey
Most companies are simply not taking the necessary actions to ensure they have reasonable prevention procedures in place, writes Oliver Pumfrey (FTI Consulting).
Tax and the City review for October 2019
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly
update on tax developments affecting the City.
Full treaty territory status changes
Will Egan
Graham Samuel-Gibbon
Graham Samuel-Gibbon and Will Egan (Taylor Wessing) consider HMRC's updated list of double tax treaties and the tax implications for groups with entities in those jurisdictions.
HMRC’s updated business risk review: BRR+
Laura Harper BDO
HMRC's revised business risk review process is due to launch on 1 October. Laura Harper (BDO) provides an advance preview.
New EU double tax dispute resolution mechanism
The UK has published draft regulations adopting an EU directive that promises faster resolution of double taxation disputes between member states.
Avoidance outside tax: a new turn for Ramsay
Dominic Stuttaford
Sofia Casselbrant
Sofia Casselbrant-Multala and Dominic Stuttaford (Norton Rose Fulbright) examine the Court of Appeal decision in
Rossendale
that demonstrates the potential general application of the
Ramsay
approach, but clearly shows its limits as a means of countering avoidance.
IR35: what happens to the 90%?
Jason Collins
Jason Collins (Pinsent Masons) highlights the measures that personal service
companies need to put in place to minimise the effect of not complying with
the IR35 rules.
UK implementation of DAC 6
Zoe Andrews
Zoe Andrews (Slaughter and May) takes a first look at the UK draft regulations implementing the EU's cross-border reporting rules.
Relocation, relocation, relocation
Penny Van den Brande
Ashley Greenbank
Ashley Greenbank and Penny Van den Brande (Macfarlanes) consider the UK tax consequences for businesses considering moving assets or functions out of the UK, whether by a change of residence of a UK company, the insertion of a new, non-UK, holding company or the relocation of specific assets and functions
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EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 25 April 2025
DST was always meant to be temporary, says Exchequer Secretary
HMRC change approach to CIR reporting
R&D relief: HMRC to update guidance on going concern rules and intra-group transfers
Pre-development costs consultation postponed
CASES
Read all
WTGIL Ltd v HMRC
Vaccine Research Limited Partnership and another v HMRC
George Mantides Ltd v HMRC
Refinitiv Ltd and others v HMRC
Other cases that caught our eye: 25 April 2025
IN BRIEF
Read all
A statutory residence test bear-trap
Protected income and offshore income gains
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
MOST READ
Read all
VAT road fuel scale charges updated
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way
Loan Charge review: call for evidence
FA 2025 review: The new FIG regime: who are the real winners?