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to progress its implementation of the OECD’s Pillar Two reforms, with further legislative progress and publication of draft guidance by HMRC....more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
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
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 December 2021, the OECD published keenly awaited model rules designed to implement Pillar Two of its ambitious plans to reform international taxation. ...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
In this Great Investor Insights alert, our tax specialists examine the key issues to be taken into account by global institutional investors, fund managers and corporates in structuring UK inbound investment in the current...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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