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International taxes
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INTERNATIONAL TAXES
International review for May 2026
Tim Sarson
Tim Sarson (KPMG) reviews fresh OECD Pillar Two guidance, the CJEU’s latest VAT and Transfer Pricing decision, growing interest in Digital Services Taxes and Canada’s delayed implementation of the Under-Taxed Profits Rule.
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
Iarlaith McCarthy-Hann
Rob Sharpe and Iarlaith McCarthy-Hann (Cleary Gottlieb) examine the Finance Bill provisions.
TOMS, taxis and private hire vehicles
Damon Wright
Damon Wright (K3 Tax Advisory) examines the Finance Bill provisions.
A Budget for its times? The Scottish Budget 2026/27
Alan Barr
Isobel d'Inverno
Pre-election changes ease income tax for lower earners, while bigger tax reforms are pushed into the next parliament, report Isobel d’Inverno and Alan Barr (Brodies).
End of year musings on corporate tax
Jenny Doak
Jenny Doak (Paul Hastings) contrasts a year of relative domestic stability with
international upheaval.
Budget 2025: HMRC’s whistleblower scheme launches with limited detail
Craig Kirkham-Wilson
The Autumn Budget has confirmed the introduction of a new scheme to reward informants who help HMRC recover tax that has been avoided or evaded. Announced by James Murray MP in March 2025, the scheme is designed to incentivise...
Budget 2025: DST heading for a Clash: should I stay, or should I go now?
Patrick O'Gara
HM Treasury has presented its long-awaited report to Parliament of its mandated review of the digital services tax, the controversial two per cent levy on revenues earned from the provision of social media, search engine and online marketplace...
Budget 2025: International private client tax issues
Lynnette Bober
Helen McGhee
There were several measures introduced by the 2025 Budget that will be of particular interest to HNW internationally mobile individuals, and I highlight a few of these below. 5m IHT cap for pre-October 2024 EPTs: There will be a 5m cap...
Budget 2025: Complaints old and new: what the Budget really tells us about tax
David Milne KC
There will be the usual complaints about the tax burden on working people, but it is very modest compared with the 1960s and 1970s, when the top rate of income tax was still 98%, imposed to pay the USA for the monies lent to us for WW2. There will...
International tax reform: what are the critical issues?
Philip Baker KC
In a follow-up article to his piece on the prospects for international tax
reform, Philip Baker KC (Field Court Tax Chambers) gives a personal view of
what he sees as some of the critical tax issues that should drive international
reform – and the potential solutions.
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
Read all
Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
Read all
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
MOST READ
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HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime