European Tax

In her recent post, Zoe Andrews suggested that, given the importance for the UK of securing a post-Brexit trade agreement with the US,...

The Labour Party has been in trouble this week due to its promise to scrap the UK tax marriage allowance. This allowance was introduced...

The Tax Foundation has published its annual International Tax Competitiveness Index. Countries are ranked by competitiveness in respect...

Earlier this week, HMRC published their annual corporation tax statistics, and they provide some interesting insights into who is paying...

The European Court ruled yesterday that the EU Commission had not been able to demonstrate that the advance pricing agreement between...

In any cross-border merger transaction, an early question will often be where the holding company for the merged group should be located....

The question of how the tax regime should adapt to reflect modern working practices is a difficult one. There has been a rise in the...

The time limit for the UK to appeal the EU’s State aid decision in relation to the UK’s CFC regime is fast approaching, and we still do...

A feature of all the DSTs described in Deeksha Rathi’s earlier post is that they apply only to digital businesses that generate global...

Now that they have had a chance to digest the decision in the EU State aid investigation into certain aspects of the UK CFC rules,...

A recent UK tax tribunal decision, relating to the UK corporation tax treatment of a “tower” structure, serves as a useful reminder of...

The full decision in the EU State aid investigation into the UK CFC rules for non-trading finance profits (“NTFP”) has now been...

In the recent case of Gallaher, the UK’s First-tier Tax Tribunal reached a surprising conclusion on the UK’s intra-group transfer regime....

In 2017 the OECD asked a group (made up of the UK and Italian tax authorities) to look at how countries could ensure that income from the...