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International taxes
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INTERNATIONAL TAXES
International review for July 2024
Tim Sarson
Pressure grows for a global wealth tax. This and other recent developments in
international tax are examined by Tim Sarson (KPMG).
Disguised investment management fees: some international aspects
Robert Langston
Robert Langston (Saffery) explains why it is necessary to consider international tax principles, such as entity classification and transfer pricing, alongside the disguised investment management fee rules.
International review for June 2024
Tim Sarson
Your monthly review of latest developments, by Tim Sarson (KPMG).
Burlington in the UT: a clearer approach
Kyle Rainsford
Kyle Rainsford (Addleshaw Goddard) explains that the Upper Tribunal has
largely eschewed the FTT’s extensive reliance on UK domestic law cases on
‘purpose’ when determining whether a treaty anti-abuse provision applies.
Pillar Two: assessing the impact on the UK FTSE 100
Alistair Nichol
Lavina Hassasing
The expected impact of the new Pillar Two regime is starting to unfold as
the first UK groups have filed their calendar year-end consolidated accounts,
write Alistair Nichol and Lavina Hassasing (Evelyn Partners).
What is the UK tax treatment of Dubai (DIFC) Foundations?
Kyra Motley
Will Timbrell
There is no equivalent to a Foundation registered with the Dubai International
Finance Centre Registrar of Companies under English law. How then should
they be treated for UK tax purposes? Kyra Motley and Will Timbrell
(Boodle Hatfield) investigate.
Ask an expert: Will a virtual server give rise to a taxable presence in the UK?
Christopher Eames
A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.
International review for April 2024
Tim Sarson
The Advocate General’s opinion on the CFC Finco exemption state aid case,
new US regulations and an update on Pillar Two are among the developments
in this month’s review by Tim Sarson (KPMG).
Labour’s tax plans: aiming at the wrong target?
James Quarmby
Is Labour’s diagnosis of the tax gap accurate and has the party misjudged
its non-dom proposals, asks James Quarmby (Stephenson Harwood).
International review for March 2024
Tim Sarson
Tim Sarson (KPMG) reviews the Biden Administration’s FY 2025 tax proposals and the OECD’s new guidance on Amount B of Pillar One.
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212
EDITOR'S PICK
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
1 /7
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
,
Gabrielle Van der Haegen
2 /7
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
3 /7
The statutory residence test: ten things we find very difficult about you
Claire Weeks
,
Aoife McCauley
4 /7
Burlington in the UT: a clearer approach
Kyle Rainsford
5 /7
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
6 /7
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Deepesh Upadhyay
,
Dominic Robertson
7 /7
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
The statutory residence test: ten things we find very difficult about you
Claire Weeks
,
Aoife McCauley
Burlington in the UT: a clearer approach
Kyle Rainsford
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Deepesh Upadhyay
,
Dominic Robertson
NEWS
Read all
HMRC manual changes: 26 July 2024
Government’s ‘fiscal lock’ is welcome but ‘rather theatrical’, says IFS
EU Council reiterates concerns over UN framework
OECD’s ICAP documents
XST’s three priorities for HMRC
CASES
Read all
Centrica Overseas Holdings Ltd v HMRC
HMRC v GE Financial Investments
A Outram and another v HMRC
Other cases that caught our eye: 26 July 2024
Finanzamt T II v S
IN BRIEF
Read all
Lease extensions and the 3% surcharge
What next for ISA fractional shares?
HMRC service standards: where next?
SDLT: residential or not?
HMRC service standards: where next?
MOST READ
Read all
The dirty dozen
VAT on private school fees
The statutory residence test: ten things we find very difficult about you
Labour rules out return of pensions lifetime allowance
Reeves rules out emergency Budget