GROUPS

Tax campaigners insisted on Tuesday that the OECD’s review of the international tax system should not rule out the option of unitary taxation, while leading tax professionals warned that such a regime would create significant practical difficulties.

Robin Walduck and Peter Scholes explain the need for tax input into the decisions groups are taking on UK GAAP conversion.

Pete Miller answers a query about the taxation of demergers

Geoff Lloyd and Fiona Thomson examine how the proposed financial transaction tax may apply to UK corporate groups and the practical implications that this might have for them, focusing on derivative transactions entered into by group treasury companies.

Revised technical note includes draft legislation

David Whiscombe examines tax on transfer of a trading operation

In GKN, the taxpayer successfully obtained a substantial interim payment in the FII GLO. David Pickstone thinks that the FII group may not be the only taxpayers affected by that decision.

GAAR interim advisory panel There has been quite a bit of frustration expressed at the fact that the draft guidance on the proposed new general anti-abuse rule (GAAR) released in December included only a handful of easy examples, where the assumed...

Helen Lethaby reviews recent developments affecting the City, including the recently published draft legislation on the new annual residential property tax, developments concerning tax transparent funds and recent appointments to the GAAR interim advisory panel.

Julie Hughff considers whether greater transparency in tax will help, and examines what steps are needed to achieve it.