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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
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
Professional bodies warn against UTT expansion
Close company reporting: ‘benefits lost in a sea of data’
HMRC clarify CIS treatment of pure financing arrangements
HMRC guidance gives comfort on management rollovers
Further compensation payments exemption
CASES
Read all
Lifeplus Europe Ltd v HMRC
MyPay Ltd v HMRC
WWM (Harrogate) LLP v HMRC
Other cases that caught our eye: 12 June 2026
Bagshaw Ltd v Revenue Scotland
IN BRIEF
Read all
Information notices
Management rollovers and share-for-share exchange relief
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
MOST READ
Read all
HMRC clarify CIS financing positions
Ask an expert: Dividend planning under the new close company reporting regime
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Consultation tracker
One minute with… Jon Claypole