Recent News

Transfer pricing enquiries in the UK are getting longer, larger and more contentious. According to law firm Macfarlanes, HMRC's transfer pricing yield rose to £3.4bn in 2024/25, nearly double the previous year, while the number of settled enquiries stayed roughly flat. The average age of settled enquiries exceeded 40 months for the first time. HMRC's own targets are much shorter: 18 months for most cases and 36 months for complex or high-risk ones. How HMRC selects and runs enquiries HMRC openly says it picks transactions to enquire into largely based on the amount of tax at risk. Initial requests aim to understand how the business trades, who performs which functions, what intra-group transactions exist and where profit arises. In practice, the requests rarely stop there. HMRC goes on to interview key individuals and review contemporaneous documents such as emails. What HMRC can require from a taxpayer Information must be reasonably required to check the taxpayer's tax position. HMRC does not need to suspect a loss of tax, but it cannot go on a fishing expedition, and disproportionate requests are unlikely to qualify. The taxpayer only has to produce what is within its...

Ukraine has joined the Addendum to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (CRS MCAA Addendum). The Addendum provides the international legal basis for exchanging an expanded set of data under the updated Common Reporting Standard (CRS). What this means for Ukraine Ukraine's tax authorities will be able to receive more complete and better-structured information from foreign counterparts about financial accounts held abroad by Ukrainian tax residents. This will help the State Tax Service to: detect undeclared foreign income; identify account holders and controlling persons more accurately; improve the quality of tax risk analysis; counter tax evasion and the offshoring of income more effectively; ensure a level playing field for taxpayers who comply voluntarily. Why the standard was updated The OECD approved the updated CRS in 2023 following a comprehensive review that took into account developments in the financial sector, new financial products and practical experience. The changes cover new instruments that can serve as alternatives to traditional financial products, clarify the information to be...

HM Revenue & Customs (HMRC) has outlined key principles in its Capital Gains Manual (CG25000C) detailing how an individual's tax residence, ordinary residence, and domicile status determine their liability to UK Capital Gains Tax (CGT).The statutory framework aims to charge CGT on gains where there is a sufficient territorial connection between the individual realizing the gain and the United Kingdom.Key Highlights:UK Residents: Individuals who are UK tax residents are generally subject to CGT on their worldwide capital gains, subject to the remittance basis for non-domiciled individuals and relevant Double Taxation Treaties.Non-UK Residents and UK Property:Since April 6, 2015, non-residents disposing of UK residential property interests fall within the scope of CGT.Since April 6, 2019, the scope was expanded to cover direct and indirect disposals of all UK land and real property (including commercial property).Trade via UK Branch or Agency: Non-residents carrying on a trade, profession, or vocation in the UK through a branch or agency remain chargeable on gains from assets used for the purpose of that business.Temporary Non-Residence Rules: Anti-avoidance provisions ensure...

On July 21, 2026, the OECD published its annual Corporate Tax Statistics 2026 report, compiled from aggregated Country-by-Country Reporting data of nearly 9,400 multinational enterprises. The publication highlights an unprecedented era of global tax transparency, driven by automated data exchange protocols that allow international regulators to instantly detect mismatches between genuine economic footprint and declared corporate earnings.MetricFigureStrategic ContextMNE Revenue Share44.5%Portion of total global Corporate Income Tax paid by MNEsGlobal CIT Rate21.2%Stabilized weighted global average tax rateRegulatory FocusSubstance GapMismatches between real economic footprint and declared profitsThe findings confirm that the strategic utility of paper offshores and passive conduit structures has come to an end. Tax authorities across key jurisdictions now utilize unified CbCR datasets to gain absolute visibility into how multinational groups allocate profits, assets, and personnel worldwide. Any significant variance between local operational activity and reported taxable income automatically triggers elevated risk status.Regulatory pressure is concentrated on holding companies...

The Monetary Authority of Singapore (MAS) has taken a significant step towards facilitating international investors.Effective August 1, 2026, new rules governing the tax exemption schemes for funds and family offices (specifically under Sections 13O and 13U of the Income Tax Act) have come into force. This targeted relaxation of technical barriers aims to enhance Singapore's attractiveness as a premier global asset management hub.Key Regulatory EnhancementsThe updated MAS circular introduces three core optimizations designed to reduce the administrative burden and expand investment opportunities:Non-SFO Local Investment Liberalization: For structures without Single Family Office status (non-SFO funds),the requirement to maintain a minimum Assets Under Management (AUM) level in local investments on an annual basis has been removed. This criterion is now only tested at the point of application, granting funds greater operational freedom throughout their lifecycle.Streamlined Family Office Conditions: For Single Family Offices (SFOs), annual requirements regarding local business spending and mandatory banking accounts have been updated. These changes aim to simplify compliance...

The international tax landscape is undergoing a structural transformation. While the OECD has historically served as the primary architect of global tax rules through its BEPS framework and Pillar 1 / Pillar 2 initiatives, a powerful new actor has entered the arena: the United Nations.The UN Intergovernmental Negotiating Committee (INC), tasked with drafting the UN Framework Convention on International Tax Cooperation (UNFCITC), reached a major milestone by releasing the "Zero Drafts" of the overarching Framework Convention along with its first two early protocols.For Finance Business Service clients—owners of international corporate structures, IT enterprises, trading holdings, and family offices—this is not merely an academic policy debate. It represents an emerging global standard that will directly impact cross-border financial flows, contract engineering, and source-based tax liabilities.1. Protocol I: Source-Based Withholding Tax on Cross-Border Services & Digital EconomyHistorically, international tax architecture relied heavily on the Permanent Establishment (PE) principle: a state could only levy corporate income tax on a foreign enterprise if it maintained a...

When it comes to global expansion and wealth preservation, Switzerland remains the gold standard. Its unique three-tier tax architecture—spanning federal, cantonal, and municipal levels—transforms tax planning from a passive requirement into a dynamic growth lever.Swiss Corporate Tax SpectrumCanton CategoryEffective Rate Range*Low-Tax Cantons11.9% EffectiveHigh-Tax Cantons20.5% EffectiveNote: *Excluding Pillar II Top-UpsStrategic Value Drivers for Enterprises & InvestorsRegional Tax Arbitrage: Effective corporate tax rates range from 11.9% to 20.5% depending on canton choice, offering unprecedented structural flexibility for business setup.Innovation & Capital Protection: Organizations can leverage IP Box regimes, R&D super-deductions, and a total exemption on private capital gains for qualifying structures.Reorganization Efficiency: Tax-neutral "immigration step-ups" allow inbound enterprises to recognize and amortize hidden reserves tax-effectively over time.Proactive Pillar II Adaptation: For multinational enterprises (MNEs) exceeding €750M in consolidated turnover, Switzerland enforces a Qualified Domestic Minimum Top-Up Tax (QDMTT) and the Income Inclusion...

When your brand becomes successful, bad actors inevitably try to monetize your momentum. Today’s cybersquatters aren't just rogue individuals—they run automated, high-volume operations targeting enterprise brand equity across hundreds of web domains at once.For Chief Marketing Officers and Legal Counsel, defending a brand portfolio against these coordinated attacks used to mean a choice between two bad options: astronomical legal fees or costly brand dilution.Enter UDRP Consolidation—the high-leverage legal strategy that allows brand owners to package hundreds of infringing domain names into a single, unified complaint. Traditional Approach: 100 Domains = 100 Legal Actions = Massive Financial Drain Strategic UDRP Action: 100 Domains = 1 Consolidated Filing = Maximum ROI Why Consolidation is a Strategic Game-ChangerAccording to IP authority Alissia Shchichka, bundling disputed domains transforms domain protection from a defensive drain into an efficient, scalable operational strategy.Under Rule 10(e) of the Uniform Domain Name Dispute Resolution Policy (UDRP), arbitral centers—such as WIPO and the Forum—allow consolidated filings across major extensions (.com,...

The Delaware Division of Corporations is actively enforcing strict address requirements under Section 502 of the Delaware General Corporation Law (8 Del. C. § 502). Corporations are now under pressure to report their actual, physical business location rather than administrative placeholders.Non-compliant companies are being flagged and denied a Certificate of Good Standing. Because good standing is routinely required for venture capital financings, M&A transactions, and other major corporate events, an inaccurate address can cause unexpected delays during the critical run-up to a deal closing.Which Addresses Are Non-Compliant?Under the statute, an annual franchise tax report is non-compliant if it lists any of the following as the corporation’s principal place of business:The address of a registered agent or Delaware registered office.A virtual office, mail-forwarding service, or similar identity.A PO Box.Any other third-party, mailing, or legacy address, such as the office of the corporation’s legal counsel or accounting firm.The reported location must be the actual physical street address from which the corporation’s corporate business is directed.Guidelines for...