Market leading insight for tax experts
Subscribe
Home
Saved articles
Viewed articles
Login
Logout
E-newsletter
Advertise
About us
Help
View online issue
BROWSE BY TOPIC
Corporate Taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect Taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International Taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private Business Taxes
OMBs
Partnerships
Private Client Taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real Estate Taxes
Property taxes
REITs
Stamp Taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
NEWS
CASES
IN BRIEF
ANALYSIS
ONE MINUTE WITH
PEOPLE & FIRMS
TRACKERS
AUTHORS
ISSUE ARCHIVE
BROWSE BY TOPIC
Corporate taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private business taxes
OMBs
Partnerships
Private client taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real estate taxes
Property taxes
REITs
Stamp taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
Subscribe
Home
Saved articles
Viewed articles
View virtual issue
View online issue
Login
Logout
E-newsletter
Advertise
About us
Help
News
Cases
In brief
Analysis
One Minute With
People & Firms
Trackers
Authors
Issue Archive
SEARCH
Home
Cross border
Home
Cross border
CROSS BORDER
Deferred remuneration: HMRC update their guidance on cross-border tax and NICs
Nigel Doran
Lika Jatoeva
Nigel Doran and Lika Jatoeva (Macfarlanes) review HMRC’s updated
guidance on deferred remuneration for internationally mobile employees and
consider the resulting risks of double taxation and NICs mismatches.
Tax and the private capital sector in 2026: three key issues
Elena Rowlands
Ian Zeider
Tom Margesson
Elena Rowlands, Tom Margesson and Ian Zeider (Travers Smith) take stock
of current developments.
From adversaries to agreement: can ADR unlock tax disputes around the world?
Liesl Fichardt
Emily Au
For cross-border disputes, there remains untapped potential for ADR to
resolve the waiting lists of cases in need of resolution, write Liesl Fichardt and
Emily Au (Quinn Emanuel).
Tax and the City review for March 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
covers the decisions in
Lloyds Asset Leasing
and
Royal Bank of Canada
, as well
as HMRC’s plans to update guidance on the salaried member rules.
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Gerald Montagu (Gide Loyrette Nouel) examines the First-tier Tribunal
decision in
Lloyds Asset Leasing Ltd
.
Towards a common European withholding framework
David Wren
Reinhart Devisscher
Paul Radcliffe
Paul Radcliffe, David Wren and Reinhart Devisscher (EY) consider the next steps for the EU to develop this model, and some key areas which may need to be contemplated in light of the European Commission’s upcoming consultation.
EU freedoms in cross-border transactions
Dominic Stuttaford
Greg Branagan
Two recent decisions have sought to clarify the extent to which the EU freedom of establishment and of the movement of capital were restricted in light of various UK legislative provisions dealing with cross-border transactions and/or operations, as Dominic Stuttaford and Greg Branagan (Norton Rose Fulbright) explain.
DAC 6 update: UK narrows scope of mandatory reporting
Sandy Bhogal
Avi Kaye
Sandy Bhogal and Avi Kaye (Gibson, Dunn & Crutcher) explain the extent to which the UK government has curtailed existing reporting obligations.
Cross-border remote workers: PAYE issues
Steve Wade
Sarah Hewson
Sarah Hewson and Steve Wade (EY) examine PAYE obligations and how any UK employment tax risks can be mitigated.
How to choose your holding company location
Charles Osborne
Sara Luder
Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.
Go to page
of
36
EDITOR'S PICK
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
1 /7
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
,
Martin Verrall
2 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
3 /7
The Orsted ‘tax nothing’
Andrew Page
4 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
5 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
6 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
7 /7
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
NEWS
Read all
Founders’ Relief: tax bodies warn over eligibility and technical traps
LISA withdrawal charge reduced
HMRC confirm VAT treatment of public EV charging
Donated medicines to be zero-rated
New HMRC withholding tax guidance
CASES
Read all
N Powell v HMRC
Inngrays Ltd v HMRC
Portsmouth City Council v HMRC
Other cases that caught our eye: 6 November 2026
Abbey Group Ltd v HMRC
IN BRIEF
Read all
Distributions reform: unresolved questions
CGT: irrecoverable loans
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
MOST READ
Read all
New HMRC withholding tax guidance
Founders’ Relief: a narrow route to 10%
Tax Journal's 2026 Budget coverage
Budget 2026: Sovereign immunity - a more considered reform
CGT: irrecoverable loans