The constant feature in international tax is the ever-changing environment. As countries start to legislate for Pillar Two’s global minimum tax, the BEPS project moves from anti-avoidance measures to the implementation of a new tax. Although many international businesses will be below the size thresholds of Pillar One and Pillar Two, it is certain that the measures will have a wider impact than what may have been anticipated when the OECD returned to the subject of the digital economy.
Multi-national enterprises of all sizes will look to ensure their governance of tax matters is founded on a firm understanding and application of principles; it remains that fiscal authorities, charged with raising tax revenues and closing the tax gap, continue to focus on risks they perceive to arise from international arrangements.
This extensive work, fully updated to July 2023 by Andrew Seidler, Irfan Butt and Duncan Nott of RSM, examines the major issues of the day in international tax planning including permanent establishment, hybrids, EU law, thin capitalisation, interest deductions, withholding taxes, transfer pricing and information exchange.


SOURCE CURRENCY
2023/24 Edition

New to this edition:
> Updated for Finance Act 2023 and Finance (No 2) Act 2023;
> Updated for the UK implementation of the global minimum tax measures in Pillar Two;
> Updated tracking of the progress of the Pillar One and Pillar Two projects;
> Commentary on policy proposals from the UK, EU and OECD;
> Updated commentary on EU law and, post Brexit, the provisions embedded in UK law;
> Updated for important case law decisions.

Each key topic is illustrated with short examples, tables and checklists.

AUTHOR INFORMATION
For 2023/24 Edition

AUTHOR:
Andrew Seidler, Irfan Butt and Duncan Nott, RSM

Consultant Editor:
Robert Langston