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Double tax relief
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Double tax relief
DOUBLE TAX RELIEF
Transfer pricing changes: foreign exchange
Andrew Stewart
Andrew Stewart (BDO) explores the new transfer pricing treatment of forex movements and highlights the additional compliance burden and technical uncertainty introduced by FA 2026.
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
Matthew Rowbotham (Lewis Silkin) examines the Government’s consultation on double taxation for UK individuals in US LLCs and finds much to welcome, as well as some important issues still to resolve.
Home and away: how to go non-resident after McCabe
Oliver Marre
The Upper Tribunal’s decision in McCabe shows how difficult it can be to
challenge findings of fact when confronted with multi-factorial tests, writes
Oliver Marre (5 Stone Buildings).
Burlington in the UT: a clearer approach
Kyle Rainsford
Kyle Rainsford (Addleshaw Goddard) explains that the Upper Tribunal has
largely eschewed the FTT’s extensive reliance on UK domestic law cases on
‘purpose’ when determining whether a treaty anti-abuse provision applies.
Burlington and treaty purpose tests
Kyle Rainsford
Kyle Rainsford (Norton Rose Fulbright) examines the first UK case about the interpretation of a purpose rule in a double tax treaty which extends the recent approach of
Blackrock HoldCo 5
to the international fiscal arena.
The new Luxembourg/UK double tax treaty
Irfan Butt
Andrew Seidler
Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.
How to choose your holding company location
Sara Luder
Charles Osborne
Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.
Glencore: MAPping unchartered territory
Charlotte Anderson
Emily Szasz
Emily Szasz and Charlotte Anderson (Freshfields Bruckhaus Deringer) examine the FTT decision on
the interaction between domestic
appeals and MAPs which are
provided for in double tax treaties.
The CFC group finance exemption: EC’s final decision
Francisco Alvarez Silva
Paul Farmer
Paul Farmer and Francisco Alvarez (Joseph Hage Aaronson) analyse the European Commission’s findings and the next steps to be taken.
TJ topics: the MLI
Expert insight from advisers at Mayer Brown, Pinsent Masons and Clifford Chance.
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43
EDITOR'S PICK
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
1 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
2 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
3 /7
The new Securities Transfer Tax: business as usual?
Georgina West
4 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
5 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
6 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
7 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
NEWS
Read all
Government’s consultation reset raises questions for tax policymaking
HMRC restate VAT position on supplies of education services
Scottish ADT provisions brought into force
OECD schedules public meeting on intra-group service guidance
HMRC issue new loan charge settlement scheme guidance
CASES
Read all
The Executors of Hunt and others v HMRC
Grand Smile Design Ltd v HMRC
S Knight v HMRC
Oakwood Great Oak Ltd v HMRC
Other cases that caught our eye: 11 September 2026
IN BRIEF
Read all
HMRC get more bang for their buck
Sanctionable conduct
The end of offshore execution on secondary transactions
Tax adviser registration: deferral for investment managers
When is a trustee not a trustee?
MOST READ
Read all
Knights Developments Ltd v HMRC
The 2026 loan charge settlement scheme: the beginning of the end?
Consultation tracker
Prize draws and VAT: a lottery?
Permanent Establishment exemption: preparing for mandatory application