CORPORATE TAXES

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.

Josh Critchlow Jill Gatehouse 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.

Matthew Mortimer

Kirsten Hunt

Matthew Mortimer and Kirsten Hunt (Mayer Brown) consider the application to UK loan structures of recent changes to the UK’s anti-hybrid rules.

Elena Rowlands Emily Clark Ian Zeider

Emily Clark, Elena Rowlands and Ian Zeider (Travers Smith) give an overview of, and their verdict on, the QAHC legislation in the Finance Bill.

Jenny Doak

Enda Kerin

How friendly is the City’s tax environment when it comes to SPACs? Jenny Doak and Enda Kerin (Weil, Gotshal & Manges) examine what SPAC transactions involve and the key UK tax considerations that can arise.

Mike Lane

Zoe Andrews

Mike Lane and Zoe Andrews (Slaughter and May) consider Autumn Budget/Finance Bill measures relevant to financial institutions and the latest on international tax reform.

David Southern QC

David Southern QC (Field Court Tax Chambers) provides a guide to the tax consequences of loan transfers.

Phil Greenfield, Chloe O’ Hara and Giorgia Maffini (PwC) examine the key changes in the Inclusive Framework’s new statement.

Mike Lane

Zoe Andrews

The impact of the ruling in Almacantar, the latest on the economic crime levy and state aid issues are among the developments covered in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

Gregory Price

Sarah Ling

BEPS 2.0 and ATAD 3 represent the latest challenge to the tax status of holding companies, renewing focus on issues of substance and withholding taxes, write Gregory Price and Sarah Ling (Macfarlanes).

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