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Born in the USA
With the recent increase in international enforcement activities undertaken by the US Internal Revenue Service (IRS) and the enforcement of the US Foreign Account Tax Compliance Act (FATCA), numero
What a gift!
The ‘employee shareholder’ concept was introduced as the flagship announcement in the chancellor’s speech at the Conservative party conference in 2012.
Funding multiplication
Since its establishment in 2000, the research and development (R&D) tax credit scheme has rewarded companies prepared to invest in innovation by granting relief on all qualifying spend.
A focus on saving
The final Budget of any parliament is always a political occasion, when chancellors set out some of the issues they wish to put in front of the electorate.
Just plug in the numbers
Country-by-country reporting was officially incorporated into the OECD’s transfer pricing documentation guidance when the updated version of Chapter V to the OECD Transfer Pricing Guidelines was pu
Loss relief limits
Seasoned observers of the European Court of Justice in Luxembourg point out that there was a high-water mark in deciding cases in favour of taxpayers.
Group precedents
When considering the corporate tax implications of disposing of shares in a subsidiary, a variety of provisions must be considered.
Caught in a diversion
The autumn statement announced a new diverted profits tax (DPT) applying at a rate of 25% from 1 April 2015.
Policing the boundary
For individuals, the distinction between corporate bonds that are qualifying corporate bonds (QCBs) and those that are not can be crucial.
