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BLOG: Fourth tranche of Pillar Two Administrative Guidance: all clear for securitisations? Securitisation is a form of structured financing, whereby the credit risks associated with a specific pool of assets are segregated from the originators’ own credit risks. This is typically achieved by establishing a special purpose vehicle (SPV), which p... BLOG: The Autumn Budget 2024: Will the Budget deliver growth in UK energy and infrastructure? On 30 October 2024, the Chancellor, Rachel Reeves, delivered the first Budget under a Labour government since 2010, emphasising in her speech that “the only way to drive economic growth is to invest, invest, invest”. Transport, infrastructure, industry, t... BLOG: How does the purpose of your borrowing impact tax deductibility? It will come as no surprise that the UK imposes certain restrictions on companies’ ability to deduct interest when calculating the profits that are subject corporation tax.  One of these restrictions is the unallowable purpose rule in section 441 of ... BLOG: Borders of Smoke and Steel: The UK CBAM Consultation Response In a world where borders are often seen as barriers, greenhouse gases remain unconfined, drifting across seas and skies, untethered to nations or geographies. The United Kingdom is now primed to erect a new type of border: motivated not by exclusion, but ... BLOG: Autumn 2024 Budget: Support, prevention and deterrence to close the UK tax gap The Autumn 2024 budget sees the UK’s new Labour government act on a number its pre-election manifesto pledges (discussed here), and intentions stated in its ‘Close the Tax Gap’ document, to decrease the UK’s ‘tax gap’. This is the difference between tax c... BLOG: Who has won the MAP awards? Dispute prevention and resolution is a key theme of the OECD’s annual “Tax Certainty Day”. The 2024 edition took place in Athens on 15 November 2024. Mutual agreement procedure (MAP) and advance pricing agreement (APA) statistics were published, and award... BLOG: How do you value an APA after the Court of Appeal's decision in Refinitiv? Transfer pricing experts are used to grappling with some tricky valuation questions when it comes to intellectual property rights.  After all, to quote (butcher?) the old Ronseal adverts, “hard to value intangibles” do exactly what it says on the tin... BLOG: Partial enquiry notices – thumbs up or thumbs down? Mind the pennies and the pounds will look after themselves” is something my grandmother often said to me in days when pocket money was still dished out in shiny coins!  It seems HMRC has taken heed of this advice, too, in its pursuit of the large pro... BLOG: Purposive interpretation by the UK Supreme Court in Cobalt Data Centre In what appears to be a case confined to the application of the now expired capital allowances regime in respect of “enterprise zones”, the UK Supreme Court in Cobalt Data Centre, once again, gave an important lesson that is always worth bearing in mind f... BLOG: Impact of the US election: what does it mean for tax policy? In a special episode of Slaughter and May’s Tax News podcast, we asked Arvind Ravichandran, Tax Partner at Cravath, Swaine & Moore LLP, what U.S. tax policy may look like during a second Trump Administration.