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Trump and House Republicans take aim at the global minimum tax and domestic tax measures

Day one of the Trump administration and the impact of the new U.S. President and Republican-controlled House and Senate is being felt in many areas, including in the international tax sphere. On 20 January, President Trump...more

What does Pillar Two mean for structured finance?

Born of the OECD’s base erosion and profit shifting (BEPS) project, the Pillar Two rules introduce a global minimum corporate tax rate of 15% on multinationals of a certain size. The reforms reflect the outcome of an...more

OECD Pillar Talk: Pillar Two looming; Pillar One one step closer

European summer might well be in full swing, but that has not stopped the OECD from pushing ahead with the implementation of its Two-Pillar reforms to international taxation. (For further background on the two Pillars, see...more

UK considers changes to rules on transfer pricing, permanent establishments and diverted profits tax

HMRC has published a consultation paper anticipating reforms to the UK’s rules on transfer pricing, permanent establishments and diverted profits tax. This is a wide-ranging review and it may be that its constituent parts...more

UK moves closer to a Pillar Two reality

The UK continues to progress its implementation of the OECD’s Pillar Two reforms, with further legislative progress and publication of draft guidance by HMRC....more

A brave new world for stamp duty?

The UK government’s proposals for the reform of stamp duty have been widely welcomed; it is generally felt that modernisation and reform are long overdue in this context. Although the proposals are not intended to alter the...more

UK Budget delivers measured optimism

UK Chancellor Jeremy Hunt delivered his first full Spring Budget on Wednesday 15 March. It is interesting (that is, interesting in a rather specific tax context) that, despite the fiscal volatility of 2022, this was in fact...more

3/20/2023  /  Corporate Taxes , REIT , Sovereign Immunity , UK

OECD Pillars: Full steam ahead

2023 is set to be a year of change for the global tax landscape. After many years of negotiation, development and consultation, implementation of the OECD’s Pillar One and Pillar Two reforms to international taxation is now...more

UK commits to global minimum tax rate

The UK government has used the opportunity of its Autumn Statement 2022, delivered on 17 November, to confirm that the Finance Bill 2022 will include legislation introducing a 15% global minimum corporation tax rate, to have...more

20 Questions for Qualifying Asset Holding Companies (QAHCs)

The Finance Act 2022 (FA22) has introduced a new regime for qualifying asset holding companies (“QAHCs”). The new regime, which came into force on 1 April 2022, offers qualifying companies a wide range of tax benefits,...more

Qualifying Asset Holding Companies (QAHCs): A new UK tax regime for alternative fund structures

On 20 July 2021, the UK government published further details of, and draft legislation for, a new elective tax regime for alternative fund structures. Although certain aspects have yet to be clarified, the proposals have...more

OECD Pillars, the digital economy and minimum taxes

To date, 132 jurisdictions have committed to the OECD’s two-pillar plan to reform international tax rules, as set out in its statement of 1 July 2021. Although the genesis of the proposed reforms relates to the taxation of...more

Global Tax Insights: Uncertain tax positions: preparing for further tax disclosure

The UK government is pressing ahead with its proposal to require large businesses to notify their “uncertain tax positions” to HMRC. ...more

Opportunity and optimism: Review of the UK funds regime - a call for input by the UK government

As part of its March 2020 Budget, the UK government announced that it would undertake a review of the UK’s funds regime. Since then, the UK government has gone on to publish a series of consultations and documents, committing...more

EU Anti-Tax Avoidance Directive Published: Implications For United Kingdom Corporate Taxpayers

On 28 January 2016 the EC published a proposal for a so-called Anti-Tax Avoidance Directive. If implemented it would apply to all taxpayers who are subject to corporate tax in an EU Member State, including corporate taxpayers...more

BEPS Projects Final Report: Issues for the Investment Funds Sector

We have considered the final reports from the perspective of a typical private investment fund that focuses on illiquid assets such as private equity, infrastructure or real estate. Some of the reports contain proposals that,...more

Key issues for asset managers in 2014

In this newsletter - U.S.: - Dodd-Frank Act – Designation of asset managers as systemically important financial institutions - Volcker Rule finalised with a more limited application to covered fund activities...more

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