Pillar meaning

STOP PRESS relating to new MTT and DTT draft legislation : Section 50 and Schedule 8 of the Finance Act 2026 revise multiple elements of the MTT and DTT rules. Notably, the draft law folds in the OECD’s Administrative Guidance (January 2025), which curbs how far pre-entry deferred tax assets and liabilities—stemming from government-granted tax incentives—may be recognised when calculating a group member’s effective tax rate. That element is to be regarded as effective for accounting periods ending on or after 21 July 2025. Most remaining measures apply to periods beginning on or after 31 December 2025, albeit certain provisions may commence earlier at the option of impacted taxpayers. For further detail, see: News Analysis: Budget 2025—Tax analysis—International. These commencement dates apply to the specified measures under the MTT and DTT regimes as set out in the draft legislation and Finance Act 2026, as applicable thereafter. STOP PRESS relating to new HMRC manual on MTT and DTT : On 5 August 2025, HMRC issued a new MTT...

Evaluating a holding company jurisdiction This Checklist provides a practical template for assessing a prospective holding company jurisdiction from a tax standpoint and perspective. It should be carefully tailored to the specific deal at hand; to illustrate, rules on interest withholding are generally immaterial where no interest payments are anticipated in the circumstances. For a Practice Note that explains the general tax concerns, issues and aims summarised in this Checklist when selecting the location of a holding company or an intermediate holding vehicle for an international enterprise (or a segment of such an enterprise) or a fund, consult Practice Note: Holding company jurisdictions—tax considerations...

This timeline outlines key developments relating to the Capital Requirements Directive IV (Directive 2013/36/EU) (CRD IV) and the Capital Requirements Regulation (EU) 575/2013 (EU CRR) from January 2024 onwards. For earlier developments, see: Capital Requirements Directive IV (CRD IV) and Capital Requirements Regulation (CRR)-timeline [Archived]. 2026 8 May 2026 - EBA The EBA consults on amendments to the RTS on the assignment of risk weights to specialised lending exposures under the Supervisory Slotting Criteria Approach. Consultation on Regulatory technical standards on specialised lending exposures. The European Banking Authority (EBA) is seeking views on proposed changes to its regulatory technical standards (RTS) governing how risk weights are allocated to specialised lending under the Supervisory Slotting Criteria Approach (SSCA). The update reflects revisions introduced by the Capital Requirements Regulation (EU) 2024/1623 (EU CRR3) and is intended to improve the framework’s risk sensitivity, clarity and usability. Collectively, the RTS pursue a harmonised and sound prudential treatment of specialised lending exposures under the SSCA...

In this issue: Lending Security Debt capital markets Derivatives Cryptoassets Daily and weekly news alerts New and updated content Useful information Lending Nova Leipzig Sarl v Gravity Fitness Ltd [2025] EWHC 1262 (Comm) An application to the Commercial Court sought a stay on the basis of forum non conveniens. The court held that Gravity Fitness Limited, an English company, had not satisfied its burden on the ‘More Appropriate Forum’ question. The defendant’s reliance on the potential application of German law was insufficient to establish that Germany was a more suitable forum than England, whether viewed from the parties’ interests or the broader interests of justice. Security Brooke Homes (Bicester) Ltd v Portfolio Property Partners Ltd (in administration) [2025] EWHC 1305 (Ch) This dispute examines equitable rights and duties between secured creditors after development land was sold by the first-ranking mortgagee, Desiman. The second-ranking creditor, Brooke Homes, sought an equitable account and pressed...

In this issue: Employment taxes VAT International Individuals and income tax Taxes management and litigation Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Employment taxes Appeal court rules that loans advanced through a remuneration trust were chargeable as disguised remuneration and that the linked costs were non-deductible (Marlborough DP Limited v HMRC). In Marlborough DP Ltd, the Court of Appeal dismissed the taxpayer’s case and upheld the Upper Tribunal (UT). It found that amounts lent to a director under a remuneration trust fell within the disguised remuneration regime in Part 7A of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003), as they were made in connection with employment. The Court further concluded that the associated payments were not allowable for corporation tax, since they were not incurred wholly and exclusively for the purposes of the company’s trade. See News Analysis: Court of Appeal...

In this issue: Budgets and Finance Bills Court of Protection UK taxes for Private Client HMRC Manuals updates Tax avoidance, evasion and non-compliance Pensions, insurance and tax efficient investments International Question of the week Additional Private Client updates this week Daily and weekly news alerts LexTalk®Private Client: a Lexis+® community New and updated content Dates for your diary Trackers Latest Q&A Useful information Budgets and Finance Bills Autumn Budget 2024 The Chancellor of the Exchequer, Rachel Reeves, presented the government’s Autumn Budget on Wednesday, 30 October 2024. For analysis of the consultations and statements pertinent to Private Client practitioners, see News Analyses: Autumn Budget 2024—Private Client analysis and Video analysis—Autumn Budget 2024: initial reaction from Harriet Brown, barrister at Old Square Tax Chambers. For coverage of the corporate tax themes, see News Analyses: Autumn Budget 2024—Tax analysis and Video analysis—Autumn Budget 2024: initial reaction from John Endacott,...

FORTHCOMING CHANGE relating to the future withdrawal of DST : Following OECD-led talks that produced a political accord on a two‑pillar solution in October 2021, the UK reached an understanding with the US, Austria, France, Spain and Italy to move away from DST towards the new global tax regime, using a transitional DST credit system. Under the arrangement, the UK would retain DST receipts until Pillar One became operational and, once in force, companies could credit against future UK corporation tax the difference between DST paid from January 2022 and the amount that would have arisen had Pillar One applied instead. In exchange, the US, which regards digital services taxes as discriminatory towards US companies, agreed to withdraw proposed retaliatory tariffs on certain US imports from the other five countries, and undertook not to pursue additional trade measures against those states because of their digital services taxes until the interim period concluded. This understanding was subsequently extended by all six countries to 30 June 2024, from an original end...

What is exchange of information? Exchange of information (EOI) among tax authorities has long stood as a key pillar of international co-operation in tax matters. In more recent years, growing levels of public and governmental concern about perceived tax avoidance—at both the individual and the corporate level—have elevated the subject still further, ensuring that EOI has become a centrally important (and arguably more effective) cross-border anti-avoidance measure. There are numerous regimes and instruments pursuant to which authorities such as HMRC exchange information relating to taxpayers with overseas tax authorities, in accordance with those frameworks. The primary focus of this Practice Note is the approach to EOI taken under double tax treaties or conventions (DTTs), although the other principal platforms through which EOI operates are also summarised. In most cases, DTTs contain a specific provision dealing with the exchange of information, and that provision is often based on Article 26 of the Organisation for Economic Co-operation and Development (OECD) Model Tax Convention (MTC)...

In October 2021, countries participating in the Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) (the OECD Inclusive Framework) endorsed a ‘two-pillar’ package addressing the tax issues stemming from the digitalisation of the global economy. The two pillars constitute an ambitious effort to reform and modernise international tax rules that allocate where, and how, profits are taxed. Pillar One is chiefly (though not exclusively) aimed at the digital economy: ‘a world where enterprises can effectively be heavily involved in the economic life of different jurisdictions without any significant physical presence and where new and often intangible value drivers increasingly come to the fore’. Pillar One introduces two elements: a new taxing right that stretches beyond traditional tax nexus rules anchored in physical location (Amount A) a standardised methodology for transfer pricing baseline marketing and distribution activities between related parties (Amount B). This Practice Note provides a high-level summary of: the tax...