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As far back as 2001, the UN noticed the relevance and importance of allocating appropriate value to activities within as well as between multinationals.

On Budget day, 29 October 2018, Chancellor Phillip Hammond announced the arrival of a new UK tax: the Digital Services Tax, or ‘DST’ as it is likely to be commonly referred to by the time we go to

Domicile: a difficult question

The law of domicile is not tax law at all – but as most practitioners will be aware, an individual’s domicile can have wide-ranging consequences for their t

New restrictions on the amount of brought forward corporation tax losses which can be offset in any one year took effect from 1 April 2017.

By highlighting over US$50 trillion worth of tax base assets at stake, Brand Finance’s Global Intangible Finance Tracker (GIFTTM) 2018 exposes the need for tax payers and tax authorities to pay att

Deep divisions

The BEPS Inclusive Framework has committed as part of the on-going work following BEPS to bring forward a new chapter of the OECD Transfer Pricing Guidelines providing guid

New restrictions on the amount of brought forward corporation tax losses which can be offset in any one year took effect from 1 April 2017.

As globalisation has continued apace in the early 21st Century, peoples’ lives in the Caribbean region have been transformed by the digital revolution: changing how they buy goods and services and

In December 2015, the European Commission announced it had opened an in-depth investigation into rulings granted by Luxembourg to McDonald’s.

Implementation date

As the government recognises, implementing the very significant changes proposed for CGT by April 2019 will be challenging for taxpayers and for HMRC.