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INTERNATIONAL TAXES


Disguised investment management fees: some international aspects premium
Card image Robert Langston
Robert Langston (Saffery) explains why it is necessary to consider international tax principles, such as entity classification and transfer pricing, alongside the disguised investment management fee rules.
10 July 2024
International review for June 2024 premium
Card image Tim Sarson
Your monthly review of latest developments, by Tim Sarson (KPMG).
26 June 2024
Burlington in the UT: a clearer approach starpremium
Card image Kyle Rainsford
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.
20 June 2024
Pillar Two: assessing the impact on the UK FTSE 100 premium
Card image Alistair Nichol
Card image Lavina Hassasing
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).
5 June 2024
What is the UK tax treatment of Dubai (DIFC) Foundations? premium
Card image Kyra Motley
Card image Will Timbrell
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.
5 June 2024
Ask an expert: Will a virtual server give rise to a taxable presence in the UK? premium
Card image 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.
29 May 2024
International review for April 2024 premium
Card image 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).
24 April 2024
Labour’s tax plans: aiming at the wrong target? starpremium
Card image 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).
18 April 2024
International review for March 2024 premium
Card image 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.
20 March 2024
What the Budget means for non-UK resident trusts starpremium
Card image Edward Hayes
Edward Hayes (Burges Salmon) explains what settlors and trustees should be doing now in light of the Spring Budget announcements.
13 March 2024
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