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INTERNATIONAL TAXES


Jeanette Zaman examines the structure of the new regime and the proposed general purpose exemption, which is intended to replace the current motive test

Sara Luder considers the proposed CFC regime for finance and IP companies, asking whether it will turn the tide on corporate migrations

Stephen Fiamma and Stefka Kavaldjieva look at the increasingly global reach of FATCA and its impact here

The following orders bring into effect agreements for the exchange of information between the UK and Belize, Dominica, Grenada and San Marino respectively.

The Double Taxation Relief (Qatar) Order, SI 2011/1684, brings into effect arrangements set out in a protocol which amends an agreement (SI 2010/241) between the UK and the State of Qatar.

A first-time comprehensive double taxation convention between the UK and the Republic of Armenia was signed on 13 July, HMRC announced.

Card image Heather Self David Smith (International Power) Philip Baker KC

Heather Self reviews the CFC reform proposals. Plus David Smith provides a view from business and Philip Baker QC considers whether the proposed rules comply with EU law

Richard Clarke and Jessica McLellan provide this month's update on recent HMRC activity, including HMRC's extension of their EBT settlement proposal, a refinement in HMRC's approach to the largest partnerships and record keeping requirements for non-residents using the new statutory residence test

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