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International taxes
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INTERNATIONAL TAXES
Non-doms post-Budget: where are we now?
Helen McGhee
Lynnette Bober
Helen McGhee and Lynnette Bober (Joseph Hage Aaronson) provide an
overview of the new rules and highlight some key points to watch.
Derivatives, repos and stock loans: an overview
Tamar Ruiz
Matthew Mortimer
Matthew Mortimer and Tamar Ruiz (Mayer Brown) provide an overview
of the tax treatment of derivatives, repo and stock loan transactions for
UK companies.
International review for October 2024
Tim Sarson
The proposed US regulations on Corporate Alternative Minimum Tax, an
important CJEU decision on state aid and the Irish Budget are among the
recent developments reviewed by Tim Sarson (KPMG).
Ten questions on the Apple judgment
Dominic Robertson
Amaury de Galbert
Does the CJEU’s judgment in
Apple
signify a major shift in tax State aid
cases? Or is
Apple
likely to be a one-off? Amaury de Galbert and Dominic
Robertson (Slaughter and May) investigate.
International review for September 2024
Tim Sarson
The Irish Apple state aid case and the US electoral candidates respective tax
policies are among the recent developments reviewed by Tim Sarson (KPMG).
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
Andrew Solomon
Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
Unbridgeable divides? Recent developments do not bode well for a successful outcome to the process of reforming the international tax architecture, writes Philip Baker KC OBE (Field Court Tax Chambers).
The Court of Appeal favours form over function in GE Financial
Kyle Rainsford
In
GE Financial Investments
, the Upper Tribunal favoured the functional
interpretation while the Court of Appeal favoured the territorial, writes
Kyle Rainsford (Addleshaw Goddard).
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.
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213
EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
National Farmers' Union calls for reversal of IHT reforms
New and updated HMRC guidance on R&D
ViDA proposals agreed by ECOFIN
HMRC issue guidance on VAT returns for those exempt from MTD for VAT
Proposal to revise DAC9 to implement GloBE Information Return
CASES
Read all
Collins Construction Ltd v HMRC
M Murphy and another v HMRC
Procurement International Ltd v HMRC
Other cases that caught our eye: 8 November 2024
GCH Corporation Ltd and others v HMRC
IN BRIEF
Read all
CGT anti-forestalling measures
Close companies: take care
Pensions tax changes in the Budget
Autumn Budget 2024: a tax hike with familiar terrain
Autumn Budget 2024: tax on corporates
MOST READ
Read all
‘Arrangements’ that disqualify new EMI option grants
A tale from the frontline of SDLT
Pillar Two and funds: there is no panacea
GCH Corporation Ltd and others v HMRC
Autumn Budget 2024: IHT - APR and BPR reform