INTERNATIONAL TAXES

The Upper Tribunal in Hargreaves effectively seeks to import the Indofood concept of beneficial entitlement into domestic law. Dominic Robertson (Slaughter and May) examines the practical uncertainties this creates and questions whether the decision was correctly decided.

Ceinwen Rees and George Apps (Macfarlanes) compare the UK’s carried interest regime to European models.

Pillar Two is gathering further momentum with announcements this month from nine territories, reports Tim Sarson (KPMG).

Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).

Pillar Two implementation is gaining traction around the world, reports Tim Sarson (KPMG).

Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).

James Caldecourt, Amanda Tickel and Caroline Barraclough (Deloitte) discuss how the UK is implementing an independent trade policy against a backdrop of Brexit, Covid-19 and a global trading system under increasing strain.

The OECD’s much-awaited Pillar Two administrative guidance is among the recent developments reviewed by Tim Sarson (KPMG).

It is full steam ahead for implementation of the global minimum tax in the UK and the EU, report Mike Lane and Zoe Andrews (Slaughter and May).