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CORPORATION TAX


A survey of senior in-house tax experts, by Tax Journal in association with FTI Consulting, assesses the initial impact of the OECD’s recommendations on tackling base erosion and profit shifting.

The UK is pushing ahead with an interest barrier, following BEPS Action 4. Helen Lethaby and Helen Gunson (Freshfields Bruckhaus Deringer) examine the new UK rules which include some nasty tweaks to the OECD recommendations.
 
From 1 April 2017, there will be a substantial change to how corporation tax losses can be carried forward. Ben Jones and Dean Andrews (Eversheds Sutherland) examine the detail.
 
Karen Cooper (Cooper Cavendish) reviews the proposed changes to disguised remuneration and recaps the recent changes to date.
 

Tax insurance for M&A deals has been around for a while, but is now becoming broader in scope, and much more common. David Wilson (Davis Polk) provides an overview.

The European Commission’s Anti-Tax Avoidance Directive shows that the Commission clearly doesn’t trust member states of the EU to implement the OECD’s BEPS 2015 recommendations, write Zoe Wyatt & Tom Wesel (Milestone International Tax Partners). 

A non-confidential version of the Commission’s ‘McDonald’s’ decision has been published, reports Pierre-Régis Dukmedjian & Alejandro Dominguez (Simmons & Simmons Luxembourg LLP).

John Whiting (Office of Tax Simplification) outlines the OTS’s new project on reviewing the corporation tax computation.
 
Cristiana Bulbuc (Joseph Hage Aaronson) considers when tax planning spills into unacceptable practices.
 

Gary Richards considers the relevance of IR35 in the light of the recent Office of Tax Simplification’s reports on small company tax and closer alignment of tax and NICs.

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