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International taxes
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International taxes
INTERNATIONAL TAXES
ATAD 3: what are the consequences of being a shell?
Ashley Greenbank
Sarah Ling
Ashley Greenbank and Sarah Ling (Macfarlanes) examine what the tax consequences of ATAD 3 will be in practice for four structures involving EU shell companies.
International review for April 2022
Tim Sarson
BEPS 2.0 and the US FY 2023 Budget are among the recent developments examined by Tim Sarson (KPMG).
Dicey Rule 3: the Court of Appeal’s decision in Skat v Solo
Dilpreet K. Dhanoa
Philip Baker KC
The Court of Appeal has upheld SKAT’s claims. Philip Baker QC and Dilpreet K. Dhanoa (Field Court Tax Chambers) analyse whether, from a legal and international tax perspective, this was the correct decision.
International review for March 2022
Tim Sarson
OECD commentary on the pillar two model rules and the responses to the pillar one public consultations are among the recent developments examined by Tim Sarson (KPMG).
International review for February 2022
Tim Sarson
Pillar one, UAE’s new federal corporate tax regime, and the Indian government’s Union Budget are among the recent developments examined
by Tim Sarson (KPMG).
International review for January 2022
Tim Sarson
Tim Sarson (KPMG) reports on a busy start to what promises to be an eventful year for the international tax world.
International review for November 2021
Tim Sarson
Tim Sarson (KPMG) reviews some of 2021’s key international tax developments and consider what’s in store for these next year.
International review for October 2021
Tim Sarson
Progress on BEPS 2.0, the EU’s public CBCR directive and plans for a new EU withholding tax system are among recent developments examined by Tim Sarson (KPMG).
Does the international agreement on the OECD pillars mark the end of trade wars on digital taxes?
Brin Rajathurai
Lorand Bartels
The recent international agreement on the OECD’s two-pillar approach is intended to take unilateral digital tax measures off the table and put an end to these trade wars. But that does not necessarily mean there is no further role for trade law in this area, write Brin Rajathurai and Lorand Bartels (Freshfields Bruckhaus Deringer).
Jersey’s economic substance for partnerships rules
Rupert Lee
New legislation brings certain partnerships within the scope of Jersey’s economic substance regime. Rupert Lee (Deloitte Jersey) reports.
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215
EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 12 September 2025
Secondary NICs on partnerships an equitable option, says report
Conveyancing and SDLT ‘advice’ in the spotlight
ATT outlines concerns on IHT pensions proposals
Scottish aggregates tax framework brought into force
CASES
Read all
SC Arcomet Towercranes SRL
Other cases that caught our eye: 12 September 2025
Lexgreen Services Ltd v HMRC
Elphysic Ltd and others v HMRC
W Tinkler v HMRC
IN BRIEF
Read all
Tribunal orders HMRC to disclose whether it used AI in R&D claims
Second home dilemma for SDLT
Will Ms Rayner face HMRC penalties?
Loans to participators: s 455
Closing the tax gap: HMRC’s approach to ‘legal interpretation disputes’
MOST READ
Read all
Lexgreen Services Ltd v HMRC
Reshuffle at the Treasury
Pre-Budget speculation fuels rumours of bank windfall tax and landlord NICs
Elphysic Ltd and others v HMRC
EV charging added to advisory fuel rates