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When the OECD’s Base Erosion and Profit-Shifting (BEPS) action plan was announced, Action 14 (making dispute resolution mechanisms more effective) was considered to be a key counterbalance to the r

As we move towards the nirvana of a single annual fiscal event, the Spring Budget seemed like it should be a modest affair before the first Budget of the new approach. And so it turned out.

Artificial enhancement of securities

Let us suppose that there is a business which is underperforming. This could be due to any number of factors.

De Beers: the case law test

De Beers Consolidated Mines Ltd v Howe (Surveyor of Taxes) 5 TC 198 is often quoted as authority for the rule that a company is resident where its boa

The G20/OECD’s Base Erosion and Profit Shifting (‘BEPS’) project recognised at the outset that changes would be required to tax treaties to implement some of the measures to modernise the internati

There’s little doubt that public country-by-country reporting is an emotive topic for tax campaigners.

HMRC has issued its response to the Government’s public consultation on rules to limit the tax deductions that companies can claim for interest expense, along with draft legislation on 5 December 2

One of the oft-repeated phrases whenever international corporate taxation comes up is ‘tax should be based on economic activities’.

On 5 December 2016, following extensive consultation, the Government released a response document setting out its decisions on new rules for corporate interest deductibility.