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International taxes
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International taxes
INTERNATIONAL TAXES
Have changes to the UK’s CFC rules created thousands of ‘surprise’ CFCs?
Sophie Donnithorne-Tait
Serena Lee
Sophie Donnithorne-Tait and Serena Lee (Akin Gump) examine the rules using examples to illustrate outcomes pre and post January 2019.
European Commission’s tax policy 2019 to 2024: what can we expect?
Nikolaas Van Robbroeck
Jordan Serfati
1 December 2019 marks the start of the new European Commission led by incoming President Ursula von der Leyen. Jordan Serfati and Nikolaas Van Robbroeck (Freshfields Bruckhaus Deringer) consider what's in store for tax policy.
GloBE: learning the lessons of the past
Mike Lane
Accounting standards bodies could play a key role as setter of the rules for a global tax base.
UK industry bodies respond to OECD's 'pillar one' proposal
Julian Feiner
The OECD’s programme of work on tax and digitalisation is energising debate about the future of international tax, reports Julian Feiner (Clifford Chance).
International review: looking back on 2019
Tim Sarson
Tim Sarson (KPMG) reviews some of the interesting developments that
unfolded over the past year in the international tax arena.
Going GloBal: the OECD’s consultation on pillar two
Brin Rajathurai
Murray Clayson
Experts at Freshfields Bruckhaus Deringer examine the OECD's pillar two proposals which could have a fundamental impact on the way all multinationals are taxed.
Lessons from the Starbucks and FIAT state aid rulings
Wiebe Dijkstra
Arjan Kleinhout
The judgments of the General Court in the
Starbucks
and
Fiat
cases give important guidance on some of the fundamental questions concerning the application of EU state aid rules to individual tax rulings, write Wiebe Dijkstra and Arjan Kleinhout (
De Brauw Blackstone Westbroek).
Taxation of cryptoassets for businesses
Robert Langston
Robert Langston (Saffery Champness) considers new HMRC guidance that provides some clarification, although there are still areas that are left open.
Is the arm’s length principle dead?
Gary Richards
Robert Hartley
Gary Richards and Robert Hartley (Mishcon de Reya) focus on how OECD’s public consultation document on the ‘unified approach’ under pillar one sheds light on the future scope of the arm’s length principle.
Is the DST compatible with the UK’s international obligations?
Rupert Shiers
Jonathan T Stoel
The UK DST in its current form may well breach the UK’s obligations under double tax treaties, international trade law, or both, write Rupert Shiers and Jonathan T Stoel (Hogan Lovells).
Go to page
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217
EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Tax Journal thanks its July 2026 authors
GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
Read all
Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
Read all
Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
MOST READ
Read all
The VAT treatment of prize draws
The new duty to correct tax return errors
Requirements for forthcoming pensions IHT changes
Loan charge settlement scheme: regulations and guidance published
One minute with... Tim Gummer