TRANSACTIONAL TAX

Ashley Greenbank (Devereux Chambers) considers the Court of Appeal’s decision in Muller, which raises important questions about the application of the CTA 2009 s 1259 deeming rule to partnership and LLP restructurings involving corporate members.

Mark Pearce

Mark Pearce (Gateley Legal) examines the different approaches HMRC, STEP and the UK courts are taking in respect of the taxation of cryptocurrencies.

Andrew Howard

More costs are deductible than might previously have been thought, but a high bar is set for holding companies.

Brin Rajathurai

Murray Clayson

Experts at Freshfields Bruckhaus Deringer examine the OECD's pillar two proposals which could have a fundamental impact on the way all multinationals are taxed.

Brin Rajathurai

Murray Clayson

The OECD's programme of work subtly recasts the two pillars proposed in its earlier consultation, as Brin Rajathurai and Murray Clayson (Freshfields Bruckhaus Deringer) explain.

Three recent tax-related developments in the insolvency and restructuring sphere.

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.

Helen Lethaby

Helen Gunson

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.

Ashley Greenbank

Ashley Greenbank (Macfarlanes) considers the proposals for the introduction of further adjustments to counteract the financial benefits of cash flows arising from non-arm’s length transfer pricing.

Stephen Pevsner

Stephen Pevsner (King & Wood Mallesons) examines the new financial products hallmark introduced into the DOTAS rules in February. Are concerns over their scope overstated?

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