The England and Wales High Court’s recent ruling on quantification in the controlled foreign company (CFC) and dividend group litigation order (GLO) clarifies that the test claimant is entitled to recover compound interest on claims for unlawful corporation tax paid both in open and closed accounting periods. However uncertainty remains about when, and by which court or tribunal, the test claimant may recover the sums due.
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A 120-plus-day delay to refunds would cost taxpayers almost $3bn in additional interest, the Cato Institute warned; plus indirect tax updates from February
The Office for Budget Responsibility’s pessimistic pillar two forecast accompanied the UK chancellor’s muted Spring Statement, dubbed ‘as dull as possible’ by one adviser
Digital tax reform is dissolving the old ‘temporal buffer’, forcing systems, institutions, and professionals to adapt as real-time reporting reshapes governance, capability, and compliance
While some believe it could have a positive effect on the wider advisory landscape, others argue that HMRC’s ‘red tape’ exercise won’t deter bad actors
The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos
The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions