INTERNATIONAL TAXES

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.

Tim Sarson

Tim Sarson (KPMG) reports on recent developments that matter from around the globe, in a rare month of respite from BEPS 2.0.

Dominic Lawrance

Sophie Dworetzsky

Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) share their views on the current tax regime for UK resident non-domiciled individuals and what might happen under a Labour government.

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