20 Dec, 2021 OECD published model Pillar Two GloBE rules By Bezhan Salehy The OECD has today published model provisions for the Pillar Two GloBE rules, which seek to ensure multinationals pay a minimum effective...
14 Dec, 2021 A last minute tax Christmas present? By Bezhan Salehy With Christmas fast approaching, will the OECD be giving the tax community a last minute present in the form of the Pillar Two model...
14 Dec, 2021 No decision? No problem: challenging tax in the High Court By Jackelyn West In most circumstances, a decision issued by HMRC may be appealed to the First-tier Tax Tribunal or, if the dispute raises public law...
14 Dec, 2021 LIBOR transition - impact for trustees By Clare Wilson Jennifer Smithson The London Interbank Offered Rate (LIBOR) is one of the main interest rate benchmarks used in financial markets, determining interest...
10 Dec, 2021 Mind the (interpretation) gap: Governmental attitudes towards "incorrect" legal interpretations By Gideon Sanitt Victoria Braid The Times has recently reported that the Government is seeking to limit the power of the courts to overrule decisions made by ministers...
06 Dec, 2021 Executive power: the FCA implements decision-making reform By Lorna Emson James Reid The FCA recently published a policy statement outlining changes to its decision-making processes, in order to make “faster and more...
02 Dec, 2021 HMRC takes action to improve large business tax administration By Rhiannon Kinghall Were There has been growing recognition that the relationship between large businesses and HMRC has become more strained. It was therefore...
02 Dec, 2021 English law, how smart! English legal system ready to take on smart contract disputes without new legislation By James Popperwell Luke Chinniah The Law Commission has recently published advice to the Government concluding that English common law is sufficiently flexible to deal...
02 Dec, 2021 An unappealing position: lack of clarity in Dunsby v HMRC on when permission to appeal is required By Sophie Rhind The recent Upper Tribunal (UT) case of Dunsby v HMRC [2021] UKUT 0289 (TCC) has raised again the issues that parties face when appealing...
02 Dec, 2021 Tax Day: points for private client practitioners By Paul Hardwick Tuesday was the UK’s second so-called “Tax Day” and, as promised earlier this month, the Government has published various papers,...
01 Dec, 2021 IHT and CGT simplification – meaningful reform off the table following OTS review By Rhiannon Kinghall Were The duo of reviews conducted by the Office of Tax Simplification (OTS) into inheritance tax (IHT) and capital gains tax (CGT) have...
30 Nov, 2021 UK transitions to OECD mandatory disclosure rules By Jeremy McCallum Today, HMRC launched its long awaited UK mandatory disclosure rules (MDR) consultation process. The process seeks views on the design of...
26 Nov, 2021 EU proposes delay to mandatory buy-in regime; settlement fails reporting and cash penalties unaffected By Robert Daniell Edward Karsten Kartik Iyer In a much-anticipated move, EU co-legislators have proposed an amendment to the Central Securities Depositaries Regulation (CSDR) to...
25 Nov, 2021 Policy in practice episode 4: A roundup of COP26 By David Gauke Rachel Richardson David Gauke, Isobel Morton and Rachel Richardson discuss the headlines and implications from the recent COP26.
22 Nov, 2021 Paying the price: UK proposes mandatory rules for banks to compensate fraud victims By Lorna Emson James Reid The UK government has indicated that UK banks will be required to provide refunds to victims of “push payment” fraud (also known as “APP”...
22 Nov, 2021 “Yearly” interest and witholding tax duty: Hargreaves Property Holdings v HMRC By Naomi Charrington The UK has a system which requires any company paying “yearly” UK-source interest to a non-UK resident to withhold income tax from that...