Macfarlanes

In this article for Tax Journal, Bezhan Salehy, Rebecca Rose and Elvira Colomer Fatjó take a practical look at UK interest withholding...

In Tax Journal, Sarah Ling and Ellen Wildig explore the wider impact for family-controlled businesses of the upcoming reforms to business...

In a Tax Journal article, Bezhan Salehy and Sarah Ling examine whether the Pillar Two undertaxed profits rule is susceptible to challenge...

Despite attempts to coordinate implementation of the OECD’s Pillar Two project to introduce a minimum tax to a global schedule, countries...

Intra-group transfers of intangible fixed assets (IFAs) to or from LLPs are increasingly common as precursors to M&A transactions or...

In a recent Tax Journal article Rhiannon Kinghall Were and Lucy Urwin analyse the key themes that will drive tax policy in 2023. The...

The proposals to be introduced by BEPS 2.0 and ATAD 3 represent the latest challenge to the use of holding companies in corporate...

The G7 has committed to reach an equitable solution on the allocation of taxing rights for the largest and most profitable multinational...

Ashley Greenbank explains the mechanism by which the Brexit legislation incorporates EU derived law into UK domestic law at the end of...

There are many reasons why a corporate group may decide to relocate assets or functions. These may include a desire to align the company...

In the attached article, which was first published in Tax Journal, Gregory Price and Rhiannon Kinghall Were discuss the topics below....