Large Corporate
Process in place
Background R&D is a corporation tax relief that normally reduces a company’s tax bill.
Pressing reset
Artificial enhancement of securities Let us suppose that there is a business which is underperforming....
A mostly modest affair
As we move towards the nirvana of a single annual fiscal event, the Spring Budget seemed like it should be a modest affa...
New remedies
When the OECD’s Base Erosion and Profit-Shifting (BEPS) action plan was announced, Action 14 (making dispute resolution ...
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...
People mean profits
One of the oft-repeated phrases whenever international corporate taxation comes up is ‘tax should be based on economic a...
Increasing the burden
HMRC has issued its response to the Government’s public consultation on rules to limit the tax deductions that companies...