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International taxes
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INTERNATIONAL TAXES
International review for October 2025
Tim Sarson
This month’s update by Tim Sarson (KPMG) has a distinctly European
flavour, and illustrates how politics – and not always domestic politics –
influences tax policy.
OBBBA: one big beautiful guide for non-US tax professionals
Mark Saunderson
Paul McColgan
Jason Groves
Jason Groves, Mark Saunderson and Paul McColgan (Deloitte) set out
some recommendations for UK professionals advising businesses with large
US operations.
Across the pond: comparing US and UK M&A tax protections
Simon Skinner
Richard Liu
With the increasing prevalence of US buyers of UK businesses, and consequently more ‘US-style’ deals than ever, Simon Skinner and Richard Liu (Latham & Watkins) de-mystify what this means and explain the key differences in US market practice for M&A tax protections.
How to interpret double tax treaties
Kyle Rainsford
Following a recent flurry of cases, Kyle Rainsford (Addleshaw Goddard)
revisits the basic principles of interpreting tax treaties in the UK.
The future of international tax reform
Philip Baker KC
The prognosis for international tax reform does not look good, writes
Philip Baker KC (Field Court Tax Chambers).
OBBBA: a new era in Republican tax legislation
Aharon Friedman
Andrew Solomon
Andrew Solomon and Aharon Friedman (Sullivan & Cromwell) review the
One Big Beautiful Bill as a whole and look ahead to what’s next.
Legislation day 2025: R&D relief for Northern Ireland businesses
Jenny Tragner
The rushed implementation of ERIS continues to demonstrate why legislation should be properly consulted on before implementation.
OBBBA: permanent tax cuts and international adjustments
Aharon Friedman
Andrew Solomon
Andrew Solomon and Aharon Friedman (Sullivan & Cromwell) report on an
action-packed seven days in Washington.
Beard: dividends of a capital nature
Ashley Greenbank
Ashley Greenbank (Devereux Chambers) explains why form matters.
Parallel tracks
Phil Maggs
Phil Sneade
A common set of economic principles and methods underpins state aid,
competition and arm’s length analysis, write Phil Sneade and Phil Maggs
(Frontier Economics).
Go to page
of
217
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
Read all
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