INTERNATIONAL TAXES

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 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. 

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

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

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).