TAX POLICY ADMINISTRATION

As public CbCR regimes expand, AI tools could be used to reveal patterns in global tax data, writes Will Morris (PwC).

Ruby Hamid

The new fraud offence is a notable expansion of the failure to prevent (FTP) model creating corporate criminal liability. Ruby Hamid and Nicholas Gardner (Ashurst) examine actions for companies, and compare the rules with the existing FTP offences for bribery and tax evasion.

Mark Saunderson Paul McColgan Jason Groves

Jason Groves, Mark Saunderson and Paul McColgan (Deloitte) set out some recommendations for UK professionals advising businesses with large US operations.

Angela Savin

Andrew James

Angela Savin and Andrew James (KPMG Law) explain how HMRC are aiming to reduce the ‘legal interpretation’ tax gap by urging taxpayers to disclose ‘novel or uncertain positions’.

Simon Skinner

Richard Liu

With the increasing prevalence of US buyers of UK businesses, and consequently more ‘US-style’ deals than ever, Simon Skinner and Richard Liu (Latham & Watkins) de-mystify what this means and explain the key differences in US market practice for M&A tax protections.

Kyle Rainsford

Following a recent flurry of cases, Kyle Rainsford (Addleshaw Goddard) revisits the basic principles of interpreting tax treaties in the UK.

Philip Baker KC

The prognosis for international tax reform does not look good, writes Philip Baker KC (Field Court Tax Chambers).

Yousuf Chughtai

Jack Prytherch

HMRC’s newly published materials raise important questions about how taxpayers are engaging with the UTT regime in practice, writes Yousuf Chughtai and Jack Prytherch (Osborne Clarke).

Andrew Stewart

Amy Clarke

The International Controlled Transaction Schedule is expected to be introduced in the UK in the foreseeable future. Andrew Stewart and Amy Clarke (BDO) explain how to prepare.