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IPT
VAT
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CFCs
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UK competitiveness
Withholding taxes
Private business taxes
OMBs
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Private client taxes
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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
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 to restart direct recovery of tax debts
Tax agents legislation misses the target, says ICAEW
HMRC issue guidance on international employee earnings
Reserved investor funds: new technical note
Umbrella companies: new HMRC PAYE guidance
CASES
Read all
T Pawar v HMRC
MBP Europe Ltd v HMRC
Circleplane Ltd v HMRC
Other cases that caught our eye: 26 September 2025
The Prudential Assurance Company Ltd v HMRC
IN BRIEF
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More on s 455
What if HMRC win in Hotel la Tour?
Supreme Court in Prudential Assurance
The hidden costs of a cap on lifetime gifting
SDLT and the funding of a purchase by a partner
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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