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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
Charles Osborne
Sara Luder
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
ScottishPower and penalties: McKnight sent off
Rupert Shiers
,
Katharine Crossman
1 /7
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
2 /7
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
,
Martin Verrall
3 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
4 /7
The Orsted ‘tax nothing’
Andrew Page
5 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
6 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
7 /7
ScottishPower and penalties: McKnight sent off
Rupert Shiers
,
Katharine Crossman
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
NEWS
Read all
Finance Bill 2027 published: key measures
International Controlled Transaction Reporting Regulations published
Tax treatment of image rights payments: new draft guidance
SAYE bonus rates increased
ADT: Highlands and Islands exemption
CASES
Read all
Hogan Lovells Cadwalader International LLP v HMRC
HMRC v The Mersey Docks and Harbour Company Ltd
Bottled Science Ltd v HMRC
R (Thomas Holdings Ltd and others) v HMRC
Another case that caught our eye: 13 November 2026
IN BRIEF
Read all
Employees’ expenses
Closing the tax gap: what should taxpayers expect?
Interest withholding tax: a partial solution
Founders’ Relief
Distributions reform: unresolved questions
MOST READ
Read all
Founders’ Relief: a narrow route to 10%
Tax Journal's 2026 Budget coverage
New HMRC withholding tax guidance
Budget 2026: Sovereign immunity - a more considered reform
Distributions reform: unresolved questions