INTERNATIONAL TAXES

Tim Sarson

Your monthly review of latest developments, by Tim Sarson (KPMG).

Kyle Rainsford (Addleshaw Goddard) explains that the Upper Tribunal has largely eschewed the FTT’s extensive reliance on UK domestic law cases on ‘purpose’ when determining whether a treaty anti-abuse provision applies.

Lavina Hassasing

Alistair Nichol

The expected impact of the new Pillar Two regime is starting to unfold as the first UK groups have filed their calendar year-end consolidated accounts, write Alistair Nichol and Lavina Hassasing (Evelyn Partners).

Will Timbrell

Kyra Motley

There is no equivalent to a Foundation registered with the Dubai International Finance Centre Registrar of Companies under English law. How then should they be treated for UK tax purposes? Kyra Motley and Will Timbrell (Boodle Hatfield) investigate.

Christopher Eames

A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.

Tim Sarson

The Advocate General’s opinion on the CFC Finco exemption state aid case, new US regulations and an update on Pillar Two are among the developments in this month’s review by Tim Sarson (KPMG).

James Quarmby

Is Labour’s diagnosis of the tax gap accurate and has the party misjudged its non-dom proposals, asks James Quarmby (Stephenson Harwood).

Tim Sarson

Tim Sarson (KPMG) reviews the Biden Administration’s FY 2025 tax proposals and the OECD’s new guidance on Amount B of Pillar One.

Edward Hayes

Edward Hayes (Burges Salmon) explains what settlors and trustees should be doing now in light of the Spring Budget announcements.

Meenakshi Iyer

Joel Kara

Meenakshi Iyer and Joel Kara (BDO) review the outcome of the consultation on reforms to the UK’s transfer pricing, permanent establishments and diverted profits tax rules.

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