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CROSS BORDER


Matthew Hodkin and Susie Brain (Norton Rose Fulbright) consider HMRC's proposed approach to implementation and how reporting is likely to work within the context of the UK tax system. 

The OECD's programme of work subtly recasts the two pillars proposed in its earlier consultation, as Brin Rajathurai and Murray Clayson (Freshfields Bruckhaus Deringer) explain.
Paul Farmer and Francisco Alvarez (Joseph Hage Aaronson) analyse the European Commission’s findings and the next steps to be taken.

The Commission neatly shifts its position on the UK’s CFC rules, writes Paul Davison (Freshfields Bruckhaus Deringer).

Substantial changes have been made to the profit fragmentation anti-avoidance since the original consultation was published, writes Mark Saunders (PwC).

Timothy Lyons QC (39 Essex Chambers) considers the interaction of our laws with Europe since 1973 and looks to what the future might hold.
 

Examining the CBC reporting notification requirements in the UK.

Michael Cullers and Robert O’Hare (Squire Patton Boggs) examine a US Supreme Court decision that could have far-reaching ramifications for international entities carrying on business in the US.
 
Brin Rajathurai and Helen Gunson (Freshfields Bruckhaus Deringer) consider practical issues surrounding the new cross-border disclosure rules.
 
Michael Conlon QC (Temple Tax Chambers) considers what can be learnt from the recent Court of Appeal decision.
 
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