INTERNATIONAL TAXES

The UK currently treats sovereign immunity as a principle of international law under which one sovereign state cannot impose its laws, including its tax laws, on another sovereign. Accordingly, all UK source income and gains received by a sovereign...

Sandy Bhogal

Graham Crocker

In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) agreed a Two-Pillar Solution to address the tax challenges arising from the digitalisation of the economy. Pillar One of the Two-Pillar Solution contains two...

Julius Konstantin Berling

Liesl Fichardt

Liesl Fichardt and Julius Berling (Quinn Emanuel) examine OECD, EU and UN initiatives to improve international tax dispute resolution, as well as the increasing use of domestic alternative dispute resolution.

Paul Rattew

John Endacott

John Endacott and Paul Rattew (PKF Francis Clark) examine proposed reforms to company distributions and the taxation of value extracted by private shareholders.

Evelyne Bagdassarian Gerald Montagu José Ramón Vizcaíno

A letter from Paris and Madrid, coupled with some reflections on the proposed direct tax Omnibus Directive/Recast DAC 6 Directive and recent Court of Appeal judgments, by Evelyne Bagdassarian, José Ramón Vizcaíno and Gerald Montagu (Stephenson Harwood).

A detailed report by Lexis+® UK Tax, with additional practitioner insight.

Tim Sarson

Tim Sarson (KPMG) reviews fresh OECD Pillar Two guidance, the CJEU’s latest VAT and Transfer Pricing decision, growing interest in Digital Services Taxes and Canada’s delayed implementation of the Under-Taxed Profits Rule.

Iarlaith McCarthy-Hann

Rob Sharpe

Rob Sharpe and Iarlaith McCarthy-Hann (Cleary Gottlieb) examine the Finance Bill provisions.

Damon Wright

Damon Wright (K3 Tax Advisory) examines the Finance Bill provisions.

Alan Barr

Isobel d'Inverno

Pre-election changes ease income tax for lower earners, while bigger tax reforms are pushed into the next parliament, report Isobel d’Inverno and Alan Barr (Brodies).

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