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International tax reform: public consultation on Pillar One The OECD’s public consultation on the blueprints for international tax reform took place on 14 and 15 January and recordings are available to watch on OECD Web TV. This post looks at the consultation responses on Pillar One which seeks to re-allocat... Hong Kong Resolution Regime: Stay Rules and terms to be included in certain bank group contracts The Hong Kong Monetary Authority (HKMA) is taking a practical approach to its proposals for bank groups to include contractual stay/suspension provisions to buttress Hong Kong’s resolution regime. The proposals are limited in scope.  Bank gro... Employment Bulletin - January 2021 Restrictive covenants; detriment related to union activities; pregnancy discrimination; Partnership named in employment contract was the correct employer; EAT guidance on treatment of agency workers Restrictive covenants for financial adviser were unenfo... Competition & Regulatory Newsletter (23 December 2020 - 12 January 2021) European Commission conditionally approves proposed merger of Fiat Chrysler Automobiles and Peugeot The European Commission conditionally approved, after a Phase II investigation, the proposed merger between Fiat Chrysler Automobiles N.V. and Peugeot S.A... Insurance Outlook 2021 2020 was a year like no other in recent history and 2021 has started in a similar vein. From an insurance sector perspective, as well as dealing with the impact of the COVID-19 pandemic, firms have been grappling with final preparations for Brexit, the pr... ISDA 2020 IBOR Fallbacks Protocol: Corporates may adhere without fee up to 24 January 2021 We highlight the upcoming deadline of 24 January 2021 for corporates to be able to sign up to the ISDA 2020 IBOR Fallbacks Protocol without paying a fee. We highlight the upcoming deadline of 24 January 2021 for corporates to be able to sign up to the IS... UK tax after IP completion day Although the UK left the EU at 11pm on 31 January 2020, most people would not have noticed any change because the effect of the transitional arrangements under the UK-EU Withdrawal Agreement deferred many of the legal effects of Brexit in UK law. The UK w... Reflections on the EU-UK Co-operation Agreement The EU-UK Trade and Co-operation Agreement (the TCA), which came into provisional effect at 11pm on 31 December, is welcome in terms both of what has been achieved, and in providing a more cordial basis for future EU-UK relations and co-operation. The EU... Financial Institution Notices: time to press pause or reset? As mentioned in my earlier post, the UK’s proposed “Financial Institution Notices” (FINs) would give HMRC easier and quicker access to taxpayer data. Under the current rules (in Schedule 36 Finance Act 2008), tribunal approval is needed ... OECD's guidance on transfer pricing implications of COVID-19: nothing “new” in the “new normal”