CORPORATE TAXES

Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.

Following a raft of recent case law, HMRC’s has revised its guidance on the unallowable purpose rules. Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) consider what it says about HMRC’s approach to purpose-based enquiries and the situations which HMRC would normally regard as involving a tax avoidance purpose.

Mike Lane and Zoe Andrews (Slaughter and May) provide this month’s round-up that includes Spring Finance Bill measures affecting financial services.

As contract terminations proliferate in uncertain economic times, Eloise Walker (Pinsent Masons) looks at the tax issues arising from terminating an acquisition before it completes.

Mike Lane and Zoe Andrews (Slaughter and May) examine recent decisions of interest and the latest transfer pricing and diverted profits tax statistics.

Tomás McGrath and Dominic Robertson (Slaughter and May) discuss pitfalls and practical tips when considering earn-outs in M&A transactions.

James Caldecourt, Amanda Tickel and Caroline Barraclough (Deloitte) discuss how the UK is implementing an independent trade policy against a backdrop of Brexit, Covid-19 and a global trading system under increasing strain.