Chris Morgan reviews topical developments, including HMRC's new guidance on beneficial ownership in relation to double tax treaty claims.
Jon Hills on establishing whether a company is small, medium or large for the purposes of the UK transfer pricing rules.
The CIOT has welcomed draft legislation introducing a statutory definition of residence for tax purposes. Budget 2012 announced that ‘ordinary residence’ would be abolished from 6 April 2013 but overseas workday relief would be retained and put it on a statutory footing.
Chris Morgan considers the implications of the CJEU Santander case concerning withholding tax on cross-border dividends.
An OECD working party on the transfer pricing aspects of intangibles has invited comments on a discussion draft containing proposed revisions to Chapter VI (Special considerations for intangible
In the first of a new series, Alison Lobb and Clive Tietjen review international developments in the transfer pricing arena
Peter Cussons examines the impact of the decision.
The Public Bill Committee on the Finance Bill met on 24 May and the following clauses were agreed without amendment:
The Income Tax (Entertainers and Sportsmen) (Amendment) Regulations, SI 2012/1359, raise the threshold above which withholding tax obligations apply to payments made to non-UK resident entertainers and sportspeople fr
Chris Morgan provides your monthly review, including coverage of the decisions in Santander and Philips and Australia's Federal Budget.