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INTERNATIONAL TAXES
International review for February 2025
Tim Sarson
This month’s review by Tim Sarson (KPMG) includes insight on the latest
developments from the US Administration and the European Community.
ScottishPower and the limits of von Glehn
Suzanne Hill
Rupert Shiers
Rupert Shiers and Suzanne Hill (Hogan Lovells) examine a recent ruling on whether a corporation tax deduction is allowable for significant expenditure in settling a regulatory investigation.
AI in tax administration: current applications and future trends
David Hadwick
Recent scandals highlight the tension between AI and the fundamental rights
of taxpayers, writes David Hadwick (University of Antwerp).
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
Andrew Solomon
During Trump’s second presidential term, the spectre of tax cuts expanding the US federal budget deficit will fuel fierce debates between fiscally conservative and ‘pro-growth’ Republicans, write Donald L Korb and Andrew Solomon (Sullivan & Cromwell).
The Trump effect: US foreign tax policy
Tanja Velling
Among the executive orders signed by President Trump is a firm rebuff of the OECD’s two-pillar solution, writes Tanja Velling (Slaughter and May).
2024: that was the year that was
Jemma Dick
Don’t worry if you spent most of the year in a virtual queue trying to get Taylor Swift and Oasis tickets. Read Jemma Dick’s article for all you need to know about what happened in the world of tax in 2024.
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
It looks like any tax motivation is becoming fair game, writes Eloise Walker (Pinsent Masons).
The Scottish Budget 2025/26: steady as she goes, but with some stings in the tail
Alan Barr
Isobel d'Inverno
Isobel d’Inverno and Alan Barr (Brodies) review the Scottish Budget, including the new
Scotland’s tax strategy
publication which contains a wide range of substantive possibilities for change.
International review for November 2024
Tim Sarson
The tax policies of President-elect Trump and the new European Commission are among the recent developments reviewed by Tim Sarson (KPMG).
FINs: a licence to fish?
David Haworth
Rose Swaffield
Financial institution notices represent a greater power for HMRC, but this does not mean that tax managers’ hands are tied, write David Haworth and Rose Swaffield (Freshfields).
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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