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
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to progress its implementation of the OECD’s Pillar Two reforms, with further legislative progress and publication of draft guidance by HMRC....more
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 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
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
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
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
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
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
2/24/2016
/ BEPS ,
CFC ,
Corporate Taxes ,
Court of Justice of the European Union (CJEU) ,
EBITDA ,
EU ,
European Economic Area (EEA) ,
Exit Tax ,
Foreign Corporations ,
GAAR ,
Member State ,
OECD ,
Tax Avoidance ,
UK