William Watson considers the tax indemnity provision commonly found in loan facilities that follow the model promulgated by the LMA and suggests how a borrower may best resolve the issue.
Nick Farmer and Steve Hoare recap the rules in determining whether an overseas establishment is a PE, and the implications.
Tax relief for British films will be extended until the end of December 2015, HM Treasury announced folllowing receipt of EC state aid approval. The design of the scheme remains unchanged.
‘Business is “seriously concerned” about the risk of a backlash from the handling of tax avoidance disputes, according to the CBI, as it stepped into a row over the Revenue’s dealings with big companies.
Five leading tax professionals, including HMRC's Judith Knott, took part in a roundtable discussion on UK tax competitiveness. Much of the discussion, chaired by John Overs, concerned CFC reform and the potential ‘gateway’ test to filter cases out of the regime.
Chris Morgan provides a review of recent international tax developments, including the Court of Appeal decision in Marks and Spencer.
Robert Langston answers a reader's question on the international transfer of property.
MPs are set to consider whether to ‘formally call’ for Dave Hartnett to step down as HMRC’s top tax official over his handling of disputes with large companies, The Times has reported.