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Will Brexit impact on the co-operation between HMRC and European tax authorities in cross-border disputes? 

A notable feature of the current tax environment is the increasing focus o

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.

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

The US authorities are increasing their audits of foreign workers and duties undertaken by Short Term Business Visitors (STBVs).