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BEPS
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BEPS
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How to handle the new corporate interest restriction
Daniel Head
Kashif Javed
Daniel Head and Kashif Javed (KPMG) assess some of the practical challenges facing corporate groups.
The EC’s communication on digital taxation
Zoe Wyatt
Miles Dean
Zoe Wyatt and Miles Dean (Milestone International Tax Partners) examine the EC’s proposals surrounding a fair and efficient tax system in the EU for the digital single market.
TJ topics: the MLI
Expert insight from advisers at Mayer Brown, Pinsent Masons and Clifford Chance.
How ordinary loans become surprise hybrids
Jemma Dick
Dan Neidle
The definition of ‘related’ in the hybrid rules is extremely broad. Dan Neidle and Jemma Dick (Clifford Chance) explain how this could potentially cause companies to be denied interest deductions on ordinary commercial loans.
Interpreting double tax treaties in light of the BEPS multilateral instrument
Jeremy Webster
Jamie Robson
Jeremy Webster and Jamie Robson (Pinsent Masons) consider how the MLI amends existing DTTs, and examine whether the principal purpose test would apply in a given scenario.
Implementation of BEPS around the world
Philip Greenfield
Philip Greenfield (PwC) reports on the extent to which countries have started to adopt the BEPS recommendations.
The EC’s proposed reporting rules on cross-border tax planning
Martin Shah
Hatice Ismail
Gary Barnett
Hatice Ismail, Martin Shah and Gary Barnett (Simmons & Simmons) review the EC’s proposal for a directive to impose mandatory reporting obligations on intermediaries and taxpayers involved in certain cross-border tax planning arrangements.
The BEPS multilateral convention: who loves SLOBs?
Jemma Dick
Dan Neidle
The BEPS limitation on benefits article would hinder cross-border investment. Dan Neidle and Jemma Dick (Clifford Chance) consider why it’s likely to be of limited application.
International briefing for June 2017
Tim Sarson
Tim Sarson (KPMG) reviews the latest developments in the international tax world.
The diverted profits tax: two years on
Nick Gurteen
Mario Petriccione
Mario Petriccione and Nick Gurteen (KPMG) consider the impact of DPT for multinationals operating in today’s global business environment and the need to comply with the increasing tax administrative burden.
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EDITOR'S PICK
Tax Journal's 2025 Autumn Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Autumn Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
HMRC manual changes: 28 November 2025
A Budget for complexity and delayed tax rises
UK’s largest companies generated over £90bn in taxes, according to 100 Group report
Land transaction tax reliefs extended to further tax sites
HMRC Wealthy Team’s nudge letters
CASES
Read all
AD Bly Groundworks and Civil Engineering Ltd v HMRC
Milton Park Holdings Ltd and another v HMRC
J Font v HMRC
Other cases that caught our eye: 28 November 2025
HMRC v Moir Management Services Ltd
IN BRIEF
Read all
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
Yet more Budget speculation
Fixing the FIG regime before extending it
The new non-dom rules
MOST READ
Read all
Yet more Budget speculation
Meet in the middle: HMRC’s transfer pricing settlement policy
HMRC v Moir Management Services Ltd
TSI Instruments Ltd v HMRC
Saunders v HMRC