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Advisers and businesses would be wise not to hold out for finality and certainty before engaging with these highly complex and evolving...
Welcome to the European Tax Blog.
Some of Europe's brightest legal minds look at the tax issues across Europe which could impact multinational businesses.
“I see the 1.5% is being removed!” was the subject line of a client e-mail received early last Thursday afternoon in light of HMRC’s...
If we imagine a Venn diagram of two overlapping circles, A and B, and call the overlapping area C, what can we say about the individual...
For UK tax practitioners who are feeling bereft after binge-watching the final season of Succession, the ongoing series of “unallowable...
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In order to carry out a transaction, taxpayers are generally free to choose between different structures and tax regimes, and to choose...
In addition to the general anti-abuse rule (GAAR), numerous purpose tests are built into the UK tax code. Every time a new set of tax...
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Last week, HM Treasury released its Summary of Responses document to the consultation published earlier this year seeking views on the...
Across a number of European jurisdictions, relief from withholding tax may be denied where the recipient of a dividend, interest or...
Beneficial ownership (or beneficial entitlement) concepts are used across the UK tax code in relation to domestic provisions as well as...
The OECD published a second set of Administrative Guidance on the Pillar Two GloBE Rules and the GloBE Information Return (and numerous...
The short version: it seems that it has, with effect from 1 January 2024, as a result of the Retained EU Law (Revocation and Reform) Bill...
The changes proposed by the UK government in its consultation on the reform of the transfer pricing, permanent establishment and diverted...
The Upper Tribunal’s decision is a helpful ‘back-to-basics’ on the nature and purpose of the provisions on withholding tax on interest...
During a debate on the Spring Finance Bill, Gareth Davies, Exchequer Secretary to the Treasury, emphasised the UK government’s intention...
It has become a bit of a tradition that a fiscal statement is followed by a further day of tax-related announcements and publications....
Which comes first? This is the question that faced the Upper Tribunal in respect of the time of supply and VAT grouping rules in...