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  • UN adds one more dimension to transfer pricing guidance

    As the UN’s star in global transfer pricing rises, officials, taxpayers and practitioners are discussing the role it plays in shaping policy and how that affects the OECD. Sophie Ashley explores the multiple dimensions of international transfer pricing guidance.


  • David’s Goliath challenges as the new UK tax minister

    Salman Shaheen speaks to David Gauke, Exchequer Secretary to the Treasury and the man behind UK tax policy, about reform, competitiveness and tax justice.

  • Swiss deals leave anti-evasion efforts uncertain

    With Switzerland and Germany reaching agreement on a deal to prevent tax evasion through Swiss bank accounts from influencing Germans’ investment decisions, and a Swiss deal with the UK announced on August 24, Matthew Gilleard looks at where this leaves international efforts to clamp down on tax evasion.

  • How Tower MCashback could change litigation strategy

    When the UK Supreme Court ruled in favour of HM Revenue and Customs (HMRC) in the Tower MCashback decision in May concerning capital allowances, many tax practitioners lamented what the Court seemed to be saying about the tax avoidance arguments that HMRC may advance during a hearing. The decision comes at a time when HMRC is entering into more enquiries and disputes with corporate taxpayers. Erin Kelechava investigates whether the case is yet another sign of a new era defined by more contentious relationships between Revenue and taxpayers.

  • Minding the GAARs

    South American governments, particularly those in the Andean region, have only recently begun to pay more attention to extending their tax treaty networks. Anne Szustek finds out if the strategy is working as a means of prolonging strong economic growth.

  • Steering clear of officials works best for Asia

    As Europe and the US braces for a potential second economic meltdown, Asia continues to be beacon of growth with increased M&A activity and rapid business expansion. Jack Grocott speaks to the region’s tax directors to highlight the challenges they face and outline what multinationals need to consider before investing in Asia.

  • Hong Kong clause extends treaty network

    Jo-An Yee and Maurice Sae-ung of Ernst & Young explain how the adoption of a wider scope of exchange of information clause enables the rapid extension of Hong Kong’s tax treaty network.

  • Ireland to benefit from securitisation regime changes

    Finance Act 2011 introduced significant changes to Ireland’s securitisation regime, including the welcome inclusion of commodities in the list of qualifying assets for investment. The Act also introduced changes affecting the rules on the deductibility of profit participating interest and swap payments in certain cross border structures. Andrew Quinn and William Fogarty of Maples and Calder explain the benefits.

  • UK CFC reforms creeps closer to conclusion

    Gary Richards and Kevin Cummings of Berwin Leighton Paisner in London analyse the UK CFC consultation document and discover that it would be paradoxical if the new rules meant that one of the main reasons for introducing the worldwide debt cap – upstream loans – was caught by them.

  • IRS announces phased implementation of FATCA

    Thomas Humphreys, Remmelt Reigersman and Jared Goldberger of Morrison & Foerster run through the latest developments for FATCA in the US and explain that foreign financial institutions and withholding agents should benefit from additional time to comply with the rules.

  • An argument for smart tax technology in Poland

    Igor Roman of Deloitte Poland takes a look at some of the issues and explores some options for resolving the critical challenges facing companies in respect of tax reporting.

  • EU VAT implications of OTC derivative market reforms

    David Goodchild, tax counsel at Tullett Prebon, considers the principal EU VAT implications arising from the OTC derivative market reforms being implemented in the US and EU, focusing on the requirement to clear specified OTC derivative trades through a central counterparty.

News Analysis


Tax Relief

  • Tax relief

    A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to

International Correspondents

International Correspondents