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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

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to progress its implementation of the OECD’s Pillar Two reforms, with further legislative progress and publication of draft guidance by HMRC....more

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

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

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