INTERNATIONAL TAXES

Sarah Bond Rob Jones Gabrielle Van der Haegen

The FSR extends the Commission’s powers so that it can investigate subsidies granted by non-EU states to undertakings operating in the EU. Sarah Bond, Rob Jones and Gabrielle Van der Haegen (Freshfields Bruckhaus Deringer) explain the operation and implications of this regime.

Tim Sarson

This month’s review by Tim Sarson (KPMG) includes the latest batch of OECD BEPS releases and Pillar Two implementation updates from around the world.

Liam McKay

Robert Waterson

The Upper Tribunal has, for the first time, considered the meaning of ‘exceptional circumstances’ in the context of statutory residence – and it has set the bar extremely high, write Robert Waterson and Liam McKay (RPC).

Martin Shah

Martin Shah (Simmons & Simmons) reviews HMRC’s latest guidance on whether employees of overseas entities working temporarily in the UK give rise to a UK permanent establishment.

Bezhan Salehy

Deep Shah

Bezhan Salehy and Deep Shah (Macfarlanes) review the government’s extensive package of proposals that touch most areas of the UK’s transfer pricing, permanent establishment and diverted profits tax legislation.

Tim Sarson

This month’s update from Tim Sarson (KPMG).

Kyle Rainsford

Kyle Rainsford (Travers Smith) examines the ramifications of the Upper Tribunal’s decision.

A Lexis+ UK Tax report of the key announcements with additional practitioner comment.

Dominic Robertson

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.