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The impact of the OECD’s pillar two on international M&A
Brin Rajathurai
May Smith
Brin Rajathurai and May Smith (Freshfields Bruckhaus Deringer) explain how pillar two will have an uneven impact on the attractiveness of different target companies and potentially favour certain types of bidders over others.
‘Am I a shell?’ The new question facing EU entities
Laura Hodgson
Laura Hodgson (Travers Smith) explains why the proposed new rules may
require businesses to bolster the substance of their EU holding companies.
BEPS 2.0: the two-pillar approach
Ian Zeider
Laura Hodgson
Ian Zeider and Laura Hodgson (Travers Smith) provide a back to basics guide.
BEPS 2.0: the impact on financial services groups
Mark Persoff
Richard Milnes
Fehzaan Ismail
Richard Milnes, Mark Persoff and Fehzaan Ismail (EY) consider how the recent BEPS 2.0 developments may impact multinational financial services businesses.
Self's assessment: signs of a ceasefire in the digital trade war?
Heather Self
In our continuing series, Heather Self reviews tax issues that make the headlines in the national press. This week, the impact of the new US proposals on international tax reform.
The OECD’s update on international tax reform
Zoe Andrews
One step forward?
Digital taxation: a bluffer’s guide
Eloise Walker
A basic primer on ‘the taxation of the digital economy’, the story so far, and what ‘pillar 1’ and ‘pillar 2’ mean - by Eloise Walker (Pinsent Masons).
International review: looking back on 2019
Tim Sarson
Tim Sarson (KPMG) reviews some of the interesting developments that
unfolded over the past year in the international tax arena.
The transfer pricing of financing transactions: OECD guidance
Andrew Stewart
Anton Hume
We are expecting new OECD guidance on the transfer pricing analysis of financing arrangements. Anton Hume and Andrew Stewart (BDO) consider what’s most likely to change.
Is the arm’s length principle dead?
Gary Richards
Robert Hartley
Gary Richards and Robert Hartley (Mishcon de Reya) focus on how OECD’s public consultation document on the ‘unified approach’ under pillar one sheds light on the future scope of the arm’s length principle.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 19 September 2025
Chancellor commits to business rates reform
CIOT warns of ‘unintended complexity’ in APR/BPR draft legislation
Professional bodies analyse draft Finance Bill legislation
Changing the timing of land remediation relief may prove beneficial, says CIOT
CASES
Read all
The Prudential Assurance Company Ltd v HMRC
P Collingwood v HMRC
K (oao Hotelbeds UK Ltd) v HMRC
Other cases that caught our eye: 19 September 2025
SC Arcomet Towercranes SRL
IN BRIEF
Read all
Supreme Court in Prudential Assurance
The hidden costs of a cap on lifetime gifting
SDLT and the funding of a purchase by a partner
Tribunal orders HMRC to disclose whether it used AI in R&D claims
Second home dilemma for SDLT
MOST READ
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Tribunal orders HMRC to disclose whether it used AI in R&D claims
Pre-Budget speculation fuels rumours of bank windfall tax and landlord NICs
EV charging added to advisory fuel rates
Budget 2025 set for 26 November
UK-Vietnam tax treaty updated