A challenging exercise
Many readers will be familiar with the long standing principle of taxing RNDs on offshore income and gains only when the...
International Tax
International Tax
Benvenuto in Italia!
Italy opens its doors to international high net worth individuals As 2017 dawned, Italy made a big play to attract inte...
New remedies
When the OECD’s Base Erosion and Profit-Shifting (BEPS) action plan was announced, Action 14 (making dispute resolution ...
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Making it public
There’s little doubt that public country-by-country reporting is an emotive topic for tax campaigners....
Learning the instrument
The G20/OECD’s Base Erosion and Profit Shifting (‘BEPS’) project recognised at the outset that changes would be required...
Directors' meetings
De Beers: the case law test De Beers Consolidated Mines Ltd v Howe (Surveyor of Taxes) 5 TC 198 is often quoted as auth...
Rough seas ahead
Will Brexit impact on the co-operation between HMRC and European tax authorities in cross-border disputes? A notable f...
People mean profits
One of the oft-repeated phrases whenever international corporate taxation comes up is ‘tax should be based on economic a...
Hair trigger
The US authorities are increasing their audits of foreign workers and duties undertaken by Short Term Business Visitors ...
Lighten the load
In recent years governments have enacted multiple regimes that compel the automatic exchange of financial account holder...