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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
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
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
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
NEWS
Read all
Welsh tax Bill proposes repayment powers and LTT changes
Voluntary payrolling extended to accommodation and loans
Clarification sought on IHT exemption for charitable trusts
‘No separate VAT rules for cryptoassets’, HMRC say
CBAM: draft default emissions values published
CASES
Read all
ScottishPower (SCPL) Ltd and others v HMRC
T Bunting v HMRC
Brants Bridge Ltd and another v HMRC
Other cases that caught our eye: 23 October 2026
J Smith v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
The Nigel Blackwell Family Trust and others v HMRC
Chancellor reportedly rejects alignment of CGT and income tax rates
Incorporating an LLP: direct tax considerations
One minute with... Helen Miller
J Smith v HMRC