CORPORATE TAXES

Mark Bevington (ADE Tax) highlights the ‘traps’ on the operation of the pillar two model rules which might generate a tax charge when none was expected.

Zoe Andrews

Mike Lane

The Supreme Court decision in NCL Investments Ltd and the Court of Appeal decision in Skatteforvaltningen are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Zoe Andrews

Mike Lane

The Upper Tribunal decision in Royal Bank of Canada and the government’s response to the review of the UK funds regime are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Zoe Andrews

Mike Lane

Revised draft guidance on large business notification of uncertain tax treatment and the Court of Appeal’s decision in Embiricos are some of the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Jack Gifford

Chris Sanger

The debate is moving on from theory to nuts and bolts delivery. Chris Sanger and Jack Gifford (EY) examine the UK’s consultation that does little to promote tax simplification.

Bezhan Salehy

Timing differences could affect a group’s effective tax rate as much as permanent differences do, writes Bezhan Salehy (Macfarlanes).

Zoe Andrews

Mike Lane

The consultation on hedging risks for future share transactions and the FTT decision in Hargreaves are some of the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Oliver Marre

Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005.

Jill Gatehouse Josh Critchlow Alison Dickie

Jill Gatehouse, Josh Critchlow and Alison Dickie (Freshfields Bruckhaus Deringer) explore some of the interesting questions about the tax consequences of the proposed regime.