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
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
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
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to progress its implementation of the OECD’s Pillar Two reforms, with further legislative progress and publication of draft guidance by HMRC....more
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
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
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
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
The UK government is pressing ahead with its proposal to require large businesses to notify their “uncertain tax positions” to HMRC.
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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