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Consultation on the Global Anti-Base Erosion (GloBE) Proposal under Pillar Two Another day, another proposal to substantially change the international tax architecture.  This time it is the GloBE Proposal under Pillar Two. The ORIP rules: intangible property held in the Crown Dependencies It may be tempting to think that, following the renegotiation of the double tax treaties (DTTs) between the UK and the Crown Dependencies (Guernsey, the Isle of Man and Jersey), entities resident in one of them would fall outside the scope of the UK&... Tax and the City Review for November 2019 Mike Lane and Zoe Andrews look at the Tribunal decisions in Panayi and the Irish Bank case. They also consider the International Tax Competitiveness Index and the PwC report on the fiscal competitiveness of the UK for banking business. In Panayi, the FTT... Competition Law in the Digital Age This edition covers the new role for the European Commissioner as head of Competition and Digital policy, and two European reports on reforming competition policy.   Our Competition Law in the Digital Age newsletter is a quarterly publication i... Changes to the Electronic Communications Code This briefing examines the Government's proposed changes to the Electronic Communications Code, giving operators a new route to seek Code rights. The Government has responded to the consultation on the Electronic Communications Code and introduced legisla... Real Estate Newsletter Party walls, Land Transaction Tax, electronic execution, forfeiture and CVAs, email exchange, part of the land, leasehold restriction Topics include: Party walls Land Transaction Tax Electronic execution Forfeiture and CVAs - Discovery (Northampton) v De... Getting the Deal Through: Tax on Inbound Investment Gareth Miles and Tanja Velling contribute the UK chapter to this publication which provides expert local insight into the regulation of taxation on inbound investments in unfamiliar jurisdictions. Expert local insight into the regulation of taxation on i... Competition & Regulatory Newsletter European Commission imposes interim measures on Broadcom The European Commission has imposed interim measures on Broadcom in relation to exclusivity practices in TV and modem chipsets markets. The measures require Broadcom to stop applying certain provisi... The UK Stewardship Code 2020: Some key points This briefing provides a summary of the UK Stewardship Code 2020 published on 24 October 2019, and notes some of the key points and changes from the version consulted on, including the revised definition of stewardship, its revised structure and the fact ... Conforming interpretation revisited The UK’s First-tier Tax Tribunal's decision in Panayi has been published. Whilst the case was reminiscent of Gallaher  (previously discussed by Sara Luder), the Judge reached what looks like an opposing conclusion.