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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
Mike Lane
Zoe Andrews
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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87
EDITOR'S PICK
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
1 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
2 /7
The new Securities Transfer Tax: business as usual?
Georgina West
3 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
4 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
5 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
6 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
7 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
NEWS
Read all
CGT liabilities rise 89% to record £24.2bn
Pubs and hotels business rates: methodology call for evidence
Technical Note 2 for IHT on pensions
CIOT outlines support for extension of VAT online marketplace rules
VAT relief could remove barriers to social housing
CASES
Read all
Knights Developments Ltd v HMRC
A Pontin and others v HMRC
AXA Insurance UK plc and another v HMRC and another
HMRC v G Quillan
Perenco UK Ltd v HMRC
IN BRIEF
Read all
Sanctionable conduct
The end of offshore execution on secondary transactions
Tax adviser registration: deferral for investment managers
When is a trustee not a trustee?
Funding the business
MOST READ
Read all
Property 118 Ltd and another v HMRC
The end of offshore execution on secondary transactions
Knights Developments Ltd v HMRC
Perenco UK Ltd v HMRC
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