US tax reform: six key changes for international business
The long awaited US tax reform bill has been released by House Republicans. Media reports suggest that Democrat support will not to be...
TaxTube.net is live!
TaxTube.net is live! I’ve been working hard on my new audio tax news service, TaxTube, so haven’t had so much time for traditional tax...
MLI: Hot or not?
UK 5 – Netherlands 12. That may sound like a rugby score but actually it’s the number of optional anti-avoidance provisions that each...
And now for something completely different
It’s not often that I come across a term in a tax case that I don’t understand, but also have never even heard of. But recently I did,...
Tax planning disclosure and the arm’s length principle
In her recent blog on the Commission’s proposal on transparency rules for intermediaries, Paulina Szotek raises the interesting question...
Public confusion, or Some things you should know about the latest version of the EU’s public CBCR pr
When I say latest version, I mean the ‘compromise text’ of 22 June that Malta has submitted to the other 27 Member States governments, as...
The Phoenix rises – well, almost
In this world of tax uncertainty it’s no surprise that the EU FTT – or Financial Transaction Tax - is keeping us guessing whether it will...
Batting for Uncle Sam
Let me be clear: I am not an economist. But even as a tax lawyer, I can appreciate the superficial attraction (at least to some) of the...
Zero (in)tolerance (part 2)
Last time I talked a lot about zero taxation in the context of tax avoidance and evasion. What I didn’t get round to dealing with was a...
Zero (in)tolerance (part 1)
Zero has been in the tax press rather a lot recently. Often it’s about companies paying zero tax on (a lot) more than zero profits. US...