In arguing for investment into infrastructure to help rebalance the economy, Margaret Stephens and Mikko Saressalo look at how taxation can achieve this.
Nick Farmer and Steve Hoare recap the rules in determining whether an overseas establishment is a PE, and the implications.
Five leading tax professionals, including HMRC's Judith Knott, took part in a roundtable discussion on UK tax competitiveness. Much of the discussion, chaired by John Overs, concerned CFC reform and the potential ‘gateway’ test to filter cases out of the regime.
Chris Morgan provides a review of recent international tax developments, including the Court of Appeal decision in Marks and Spencer.
President Sarkozy of France is prepared to do ‘everything possible’ to get the G20 to move towards the adoption of a financial transaction tax, The Times reported ahead of this week’s G20 summit in Cannes.
A 200-strong team of investigators and specialists is targeting ‘wealthy tax cheats’ who own property abroad, HMRC said. Danny Alexander, the Chief Secretary to the Treasury, announced the creation of the ‘affluent’ unit at the recent Liberal Democrat conference.
The OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes has adopted a progress report to the G20 based on 59 peer reviews.
Governments have now signed more than 700 agreements to exchange tax information, said OECD Secretary-General Angel Gurría.
In light of the judgment, Patricia Mock and Bill Dodwell look at what it means for HMRC powers regarding extra-statutory concessions and contending residency, and legitimate expectation