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Labour's Fair Tax Programme: the £6.2bn question... ...or "Seeing as everyone else is now giving 'fact-checking a go'". When Labour published its 2019 Election manifesto last week it was accompanied by a document entitled "Funding Real Change" which set out where Labour...
Is it time to reconsider policy on bank taxation? As discussed in my Viewpoint video, the UK government is heavily reliant on taxes paid by financial services. The finance and insurance sector was the largest single contributor to corporation tax in 2017/18 accounting for 26% of corporation tax...
GloBE: learning the lessons of the past The OECD published its Pillar Two paper on the Global Anti-Base Erosion (GloBE) Proposal on Friday (Zoe Andrews' earlier post provides an overview) which requested comments on the "use of financial accounts as a starting point for the tax base...
How to choose your holding company location Sara Luder and Charles Osborne look at the tax issues which may affect where a holding company might be established, or where an existing holding company might migrate to.
Consultation on the Global Anti-Base Erosion (GloBE) Proposal under Pillar Two Another day, another proposal to substantially change the international tax architecture.  This time it is the GloBE Proposal under Pillar Two.
The ORIP rules: intangible property held in the Crown Dependencies It may be tempting to think that, following the renegotiation of the double tax treaties (DTTs) between the UK and the Crown Dependencies (Guernsey, the Isle of Man and Jersey), entities resident in one of them would fall outside the scope of the...
Tax and the City Review for November 2019 Mike Lane and Zoe Andrews look at the Tribunal decisions in Panayi and the Irish Bank case. They also consider the International Tax Competitiveness Index and the PwC report on the fiscal competitiveness of the UK for banking business.
Getting the Deal Through: Tax on Inbound Investment Gareth Miles and Tanja Velling contribute the UK chapter to this publication which provides expert local insight into the regulation of taxation on inbound investments in unfamiliar jurisdictions.
Conforming interpretation revisited The UK’s First-tier Tax Tribunal's decision in Panayi has been published. Whilst the case was reminiscent of Gallaher  (previously discussed by Sara Luder), the Judge reached what looks like an opposing conclusion. 
Freedom to move capital to (or from) overseas territories Transfers between the UK and Jersey are, according to the UK Supreme Court, within the scope of the freedom of movement of capital under what is now article 63 of the Treaty on the Functioning of the European Union. 
Tax and the City Review for October 2019 Mike Lane and Zoe Andrews review the latest corporation tax statistics; the FTT decision in Potter; the judgments in Fiat and Starbucks; and the recently published HMRC guidance on the hybrid capital instrument rules.
Dispute risk under the OECD Secretariat's “unified approach” In her overview of the OECD Secretariat's "unified approach",  Zoe Andrews mentioned that a robust dispute prevention and resolution mechanism will be needed. 
New taxing right to be an overlay to the arm’s length principle The OECD Secretariat proposal for a unified approach published today for consultation until 12 November focuses on Pillar One (nexus and profit allocation). A separate public consultation document dealing with Pillar Two (remaining BEPS issues) is...
BLOG: International Tax Competitiveness The Tax Foundation has published its annual International Tax Competitiveness Index. Countries are ranked by competitiveness in respect of specific aspects of their tax regime.
Getting the Deal Through: Tax Controversy 2020 Richard Jeens is the contributing editor of the 7th edition of this publication which summarises the framework for tax disputes in sixteen different jurisdictions, including the US and the UK. Richard Jeens, Dominic Robertson and Charles Osborne are...