Short notes from the cross-border counsel desk

Pillar Two

Two years into the EU minimum-tax directive, the local variances in QDMTT design are the real story. A field note for in-scope groups.

Alistair Thorpe · 22 Apr 2026

Transfer pricing

New tax-authority guidance on CbCR data eligibility is narrowing the safe-harbour numerator. Documentation discipline matters again.

Helena Ribeiro · 11 Apr 2026

Holding companies

The Dutch substance discussion has moved past the 2024 consultation paper. Three durable changes for holding-company structures.

Marco Conti · 28 Mar 2026

UK fund vehicles

The UK RIF went live in 2024. A year in, three things have worked as advertised and one has not.

Alistair Thorpe · 12 Mar 2026

Asia-Pacific

The Section 13U tax exemption for family-office funds was tightened in 2025. Three structural implications for groups using it as a holding vehicle.

Yuki Tanaka · 25 Feb 2026

Offshore structuring

The 2026 Cayman ES reporting cycle is the first where the substantive-test focus is fully through. Three failure modes we are seeing in early files.

Marco Conti · 8 Feb 2026

EU tax policy

National enforcement of Pillar Two diverges more than the directive's harmonisation language suggested. A practical map of the variance.

Alistair Thorpe · 30 Jan 2026

PE risk

Five years into normalised remote work, tax authorities have caught up. A short list of red flags that trigger PE enquiries in 2026.

Yuki Tanaka · 15 Jan 2026