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Double tax treaties: review of treaty policy positions
In July 2022, HMRC’s Tax Treaty Team sought input in relation to the changes to Article 5 of the OECD Model Tax Convention (MTC) as a result of the BEPS action reports and also in relation to the p
The practical challenges of identifying the right sort of trust
Testators have a range of possible trusts that can be used for partners, young children and grandchildren in their wills, including an immediate post-death interest, trusts for bereaved minors, and
The two-pillar solution to international tax: where we are now?
In October 2021, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) reached an agreement on a two-pillar solution to reform the international tax framework in response to the challenges
Inheritance tax: choosing the right sort of trust to provide for partners, children and minors
Types of will trust
Even after the changes to the inheritance tax treatment of trusts that were made in March 2006, testators have a range of possible trusts that can be used for partners
The rules of domicile: what issues can impact an individual’s tax status?
The concept of domicile links an individual to a particular jurisdiction.
The concept of 'connected persons': what are the ties that bind?
The concept of connected persons appears throughout the direct taxes legislation.
Grappling with the anomalies of inheritance tax penalties
Recently, there has been much litigation about the procedural aspects of the tax code, including several decisions of the Supreme Court on the Taxes Management Act 1970 alone.
The Global Anti-Base Erosion Model Rules (Pillar 2): CIOT responses
In October 2021, the OECD/G20 Inclusive Framework on BEPS reached an agreement on a two-pillar solution to reform the international tax framework in response to the challenges of digitalisation.
Is there a place for multiple trusts?
In the January 2022 issue of Tax Adviser, we examined the changes that had been made to trusts from 18 November 2015 in Finance (No.2) Act 2015.
