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BEPS
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BEPS
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How to handle the new corporate interest restriction
Kashif Javed
Daniel Head
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
Dan Neidle
Jemma Dick
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
Jamie Robson
Jeremy Webster
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
Gary Barnett
Martin Shah
Hatice Ismail
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?
Dan Neidle
Jemma Dick
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 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 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: 23 January 2026
New PCRT guidance clarifies ethical limits on AI use in tax
Imported hybrid mismatches
Voluntary NI contributions for periods abroad
Transfer Pricing Guidelines for Compliance
CASES
Read all
HMRC v MedPro Healthcare
J O’Neil and others v HMRC
R (oao Peter Kadas) v HMRC
Other cases that caught our eye: 23 January 2026
HMRC v Sintra Global Inc and another
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
The new share for share anti-avoidance
HMRC v Sintra Global Inc and another
Concerns over the scope of new conduct rules for advisers
Complex statutory construction: the Court of Appeal’s approach in Tower One
HMRC manual changes: 9 January 2026