Two weeks to 10 November 2023
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK.
UK
PwC previews the Autumn Statement 2023
On 22 November, the Chancellor of the Exchequer Jeremy Hunt will deliver his Autumn Statement alongside the latest economic forecast from the Office for Budget Responsibility (OBR). Ahead of the statement, the Chancellor has downplayed the prospect of tax cuts or an increase in additional borrowing. In this article, PwC tax experts, economists and industry specialists explore some of the potential measures that might be on the table and likely areas of focus. Bookmark the page so you can follow their reactions to the statement, which will be posted there following the speech. In the meantime, you can register here to join our Autumn Statement 2023 Reactions webcast, which will take place on Thursday, 23 November at 9:00am.
Case law update
Court of Appeal - corporation tax - exchange of shares
In R & C Commrs v Delinian Ltd [2023] BTC 27, the Court of Appeal upheld the decision in R & C Commrs v Euromoney Institutional Investor plc [2022] BTC 521) that avoidance of a tax liability was a purpose, but not a main purpose of the share exchange arrangements in question.
HMRC Manual & guidance updates
The following changes have recently been made by HMRC following review:
- Corporate Finance Manual
New page CFM98258 added on 1 November with information on non-sterling amounts. - International Exchange of Information Manual
Country-by-Country reporting: Exceptions to the filing obligation - Paragraph added on 1 November, suggesting reviewing the requirements listed on IEIM300050 prior to filing.
Treaty updates
- Double Taxation Treaty Passport Scheme register
HMRC has updated the register of overseas corporate lenders who are passport holders for Double Taxation Relief on UK loan interest. The register has been updated as of 2 November with 125 additions,14 amendments and 52 removals.
EU
EU declares OECD administrative guidance compatible with EU Pillar Two Directive
During the 9 November 2023 meeting of the Economic and Financial Affairs Council, the Council and Commission issued statements on the two-pillar solution to address the tax challenges arising from the digitalisation of the economy. These declare the EU Pillar Two Directive to be compatible with the OECD’s commentary and administrative guidance endorsed by the International Framework in December 2022, February 2023 and July 2023. Recognising the need to ensure consistency in order to avoid non-alignment or applicability of diverging standards, the statements effectively instruct Member states to implement legislation that aligns to that OECD Pillar Two commentary and administrative guidance rather than the EU Directive where the two conflict.
CFE Tax Advisers Europe
- EU Tax Policy News Top 5
The latest round-up of EU Tax Policy news from the Confédération Fiscale Européenne (CFE). The latest edition from 30 October includes: 1) European Parliament Adopts Resolutions on Role of Tax Policy & Reform of Corporate Tax Policy; 2) European Commission Publishes 2023 VAT Gap Report; 3) OECD Webinar on MLI to Implement Amount A of Pillar 1; 4) EU Commission & Parliament Co-host EU Tax Symposium in Brussels; and 5) OECD Updates FAQs on Model Reporting Rules for Digital Platforms. Visit their latest news page here. - Global Tax Top 10 - October 2023
The October 2023 issue looks at the following: 1) OECD Publishes Text of Pillar One Treaty; 2) European Commission Adopts 2024 Work Programme; 3) United Nations (UN) Tax Committee Meeting: 17 – 20 October in Geneva; 4) ECOFIN – Council of the EU Approves Tax Blacklist Updates & DAC8 Directive on Administrative Cooperation; 5) CFE Statement on Interest Payable on Overpayment of Taxes in Breach of EU Law (Case C-322 E v Dyrektor Izby Administracji Skarbowej we Wroclawiu); 6) European Parliament Adopts Resolutions on Role of Tax Policy & Reform of Corporate Tax Policy; 7) OECD Updated FAQs on Model Reporting Rules for Digital Platforms; 8) EU Commission & Parliament Co-Host EU Tax Symposium in Brussels; 9) EU Tax Observatory Calls for Global Minimum Wealth Tax; and 10) European Commission Publishes 2023 VAT Gap Report.
OECD
Pillars One and Two
- OECD releases Multilateral Convention to implement Amount A of Pillar One
As reported previously, the OECD recently released a package of guidance in relation to Amount A of Pillar One: the text of a consensus-based Multilateral Convention (MLC) and accompanying explanatory statement, an Understanding on the Application of Certainty for Amount A of Pillar One (UAC), and an update to the economic impact assessment of Pillar One. The OECD also published factsheets and a high-level overview of the content, operation, and layout of Amount A including a process map with steps for applying the rules. Despite running to approximately 850 pages and approved for release by the Inclusive Framework (IF), the release does not open the MLC to countries for signing at this point, because there are still issues to be resolved. Read more in our PwC Tax Policy alert - Tax Bites Podcast – Pillar One, Amount A of the Two-Pillar project: the next steps
In this episode, following the publication of the draft Multilateral Convention on Amount A and related documents on 11 October 2023, the speakers give an overview of the current state of play of Amount A. They discuss how Amount A may impact your organiSation and how to prepare for it and conclude with some key-takeaways. - OECD Webinar on the Multilateral Convention of Amount A
If you missed the OECD’s technical webinar on 26 October exploring the key features of the Multilateral Convention (MLC) to implement Amount A of Pillar One, watch the recording and find out more on the application of Amount A rules, the tax certainty framework and related issues, the removal and standstill of digital services taxes and relevant similar measures.
OECD Secretary-Generalwelcomes pledge by 48 countries to implement global tax transparency standard for crypto-assets by 2027
OECD Secretary-General Mathias Cormann has welcomed the recent announcement that 48 countries and jurisdictions intend to implement the OECD’s global tax transparency framework for the reporting and exchange of information with respect to crypto-assets by 2027. The Crypto-Asset Reporting Framework (CARF) is a key component of the International Standards for Automatic Exchange of Information in Tax Matters developed by the OECD under a G20 mandate. It provides for the automatic exchange of tax-relevant information on crypto-assets and comes against the backdrop of a rapid adoption of the use of crypto-assets for a wide range of investment and financial uses. Read more in this OECD item.
Global Forum publishes eight new peer review reports on transparency and exchange of information on request
The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) has published new peer review reports on transparency and exchange of information on request (EOIR) for six of its members (Latvia, Mauritania, Pakistan, Poland, Serbia and Thailand), and supplementary reports that reflect progress made by two members (Botswana and Dominica) in implementing the EOIR standard. Read more in this OECD news item.
The Philippines joins the Inclusive Framework on BEPS
The Philippines has joined international efforts against tax avoidance by joining the OECD/G20 Inclusive Framework on BEPS, an international collaboration with over 140 member countries and jurisdictions. Through its membership, the Philippines has also committed to addressing the tax challenges arising from the digitalisation of the economy by participating in the Two-Pillar Solution to reform the international taxation rules and ensure that multinational enterprises pay a fair share of tax wherever they operate. Read more in this OECD item.
Other territories
International
International Tax News - October 2023
International Tax News is designed to help multinational organisations keep up with the constant flow of tax developments. Among the topics featured in this month's edition are: 1) France implements Pillar Two into domestic law; 2) Malaysia expects to implement global minimum tax in 2025; 3) South Korean government considers the creation of opportunities zones with tax incentives; and 4) Mexico's tax incentives for the exportation manufacturing industry.
Digital tax byte
The latest edition in our series of brief insights into the workings of the UK and supranational bodies reviewing the taxation of digitalisation of business. In this edition, from 13 November, we cover:
- the EU Parliament's ECON committee recommendations including deferral of the VAT in the Digital Age package;
- the Netherlands has postponed the penalty regime for its VAT e-commerce One Stop Shop;
- Norway has expanded the requirements for its VAT e-commerce regime;
- Italy's issuance of a Circular on taxation of crypto assets, including digital currency.
Digital tax megabyte - October 2023
A collection of the brief insights throughout October 2023 of the type provided on an ad hoc basis in our Latest digital tax byte update (above).
Environmental, Social and Governance (ESG)
- Five ways the FTSE 100 are accelerating decarbonisation
When it comes to delivering net zero, knowing where to start can be the hardest challenge. PwC UK's latest analysis of the FTSE 100 shows how business leaders are using carbon pricing, remuneration and governance to deliver decarbonisation. Explore the insights to see how you can accelerate your organisation's net zero ambitions. Read more. - Global COP28 webcast
As we get closer to COP28, what can business leaders do to turn climate action into impactful results? Discover key topics, strategic policies, and the vital role of business in our 45-minute webcast, 'What to Expect at COP28: Making Climate Action Count". Watch on demand here.
Australia
Australia clarifies R and D tax incentive integrity rules
The Australian Taxation Office recently clarified the integrity rules that must be satisfied for research and development tax incentive claims to be accepted, and identified issues with the application of some R&D program integrity rules. The ATO urges tax agents and research and development tax consultants to review their clients' claims and voluntarily disclose any errors.
Barbados
Barbados charts a new course - the response to PillarTwo global minimum tax
Following an announcement made on 7 November 2023 by the Prime Minister of Barbados, the rate of corporation tax will increase to 9% from 1 January 2024. This increased tax rate will impact all corporate entities other than those that fall within the stipulated exclusions under the GloBE Rules.For in-scope multinational enterprises whose Ultimate Parent Entity is in a jurisdiction that has not adopted or implemented either the Income Inclusion Rule (IIR) or the Under-taxed Payment Rule (UTPR), or whose constituent entities are not subject to the IIR or UTPR, the current corporation sliding scale rates of 5.5% to 1%, established in 2019, will continue to apply. In practice, that means that some groups may continue to benefit from the current regime until January 2025, when UTPR likely comes into effect. See this PwC tax insight.
Belgium
See here for latest updates.
Cambodia
Singapore and Cambodia sign second protocol to amend their double tax treaty
A Second Protocol amending the Agreement between the Republic of Singapore and the Kingdom of Cambodia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (‘double tax treaty’) was signed on 2 November 2023. The Second Protocol amends the preamble of the double tax treaty and introduces a new Article 28 (Entitlement of Benefits), to incorporate the internationally agreed Base Erosion Profit Shifting standards for countering treaty abuse, among other technical amendments. Read more in this press release.
Canada
Canada Revenue Agency officially designates first notifiable transactions
The Canada Revenue Agency (CRA) recently designated its first set of transactions for the purposes of the recently enacted “notifiable transactions” regime, which forms part of Canada’s enhanced mandatory disclosure rules (MDR). The transactions and their related descriptions are identical to the sample designated transactions that were released on 4 February 2022, except that they: 1) are now stated to be effective 1 November 2023, and 2) no longer include the manipulation of Canadian-controlled private corporation status. Read more in this PwC Tax Insights.
Update on Québec’s Economic and Financial Situation
The Minister of Finance recently presented the Update on Québec’s Economic and Financial Situation (economic statement). The economic statement does not change corporate or personal tax rates, but does: 1) extend and enhance certain parameters of the tax credit relating to investment and innovation; 2) abolish the additional 30% capital cost allowance; and 3) adjust the exemptions allowed for the purpose of calculating the premium payable under the Public Prescription Drug Insurance Plan. This PwC Tax Insights discusses these tax incentives as set out in the economic statement.
Germany
Joint decrees: Attribution of real estate for the supplementary facts in Section 1 (2a) to (3a) of the Real Estate Transfer Tax Act (RETTA)
The long-awaited joint decrees (issued by the Supreme Tax Authorities of the Federal States) on the attribution of real estate for the purposes of the taxation of share deals (Section 1 (2a) to (3a) RETTA) recently became available. These adopt the previous case law of the Supreme Tax Court from 1 January 2021 (II R 44/18) and 14 December 2022 (II R 40/20) and illustrate the legal opinion with examples. Read more in this PwC tax blog.
Ireland
Investing in Ireland
Our latest edition explores the newly released Budget 2024, the Department of Finance Annual Taxation Report and the IDA’s 2023 half year results all from an FDI perspective.
Corporation tax declines for third consecutive month, highlighting the importance of the Government’s fiscal strategy
Ireland’s Department of Finance and Department of Public Expenditure and Reform announced in a recent press release the publication of the exchequer figures for October, revealing corporation tax has declined for a third consecutive month.
Jersey
Jersey legislates for various budget tax measures
Jersey has tabled legislation that would give effect to measures announced in the government plan for 2024 to 2027, announced in September. The Government proposes to introduce a 150% super deduction for investment in the RegTech sector, for firms innovating in the IT field to boost regulatory and compliance processes. Further, the law would align the income tax return filing deadline for Limited Liability Companies with that for companies and partnerships on 30 November.
Latvia
Global Forum publishes eight new peer review reports on transparency and exchange of information on request
The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) has published new peer review reports on transparency and exchange of information on request (EOIR) for six of its members (Latvia, Mauritania, Pakistan, Poland, Serbia and Thailand), and supplementary reports that reflect progress made by two members (Botswana and Dominica) in implementing the EOIR standard. Read more in this OECD news item.
Mauritania
Global Forum publishes eight new peer review reports on transparency and exchange of information on request
The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) has published new peer review reports on transparency and exchange of information on request (EOIR) for six of its members (Latvia, Mauritania, Pakistan, Poland, Serbia and Thailand), and supplementary reports that reflect progress made by two members (Botswana and Dominica) in implementing the EOIR standard. Read more in this OECD news item.
Middle East
Updated UAE corporate tax rules for free zones
The previously issued Cabinet Decision No 55 of 2023 and Ministerial Decision No. 139 of 2023 regarding UAE Free Zones (FZ) have been repealed and are now replaced by: 1) Cabinet Decision No. 100 of 2023 on Determining Qualifying Income (QI) for the Qualifying Free Zone Person (QFZP); and 2) Ministerial Decision No. (265) of 2023 Regarding Qualifying Activities (QA) and Excluded Activities (EA) for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (hereinafter referred to as the “CT Law”). Both new Decisions came into effect on 1 June 2023. Read more in this PwC alert.
Guide for non-resident persons for corporate tax purposes who derive state-sourced income in the UAE
The Federal Tax Authority (FTA) has clarified the criteria for determining non-residents subject to corporate tax in the UAE; the instances that require registration of a non-resident for corporate tax purposes; taxable Income and how it is calculated; as well as other requirements for compliance by non-residents subject to the Corporate Tax Law, which took effect on 1 June 2023. The FTA included a comprehensive and simplified explanation, along with general guidance, in its guide for non-resident persons, whether natural persons (individuals) or juridical persons (including public and private corporations) who derive income in the UAE, to help them determine whether they are subject to corporate tax. Read more in this FTA news item.
UAE Corporate Tax - Transfer pricing guide
On 23 October 2023, the Federal Tax Authority (FTA) issued the Transfer Pricing Guide (TP Guide), which provides insights and practical guidance to taxpayers on the Transfer Pricing (TP) rules and regulations per the Corporate Tax Law of the United Arab Emirates. The TP Guide is broadly aligned with the Transfer Pricing Guidelines issued by the OECD and provides general guidance on the TP regime in the UAE, and practical examples on, for instance: how to identify Related Parties and Connected Persons; how to undertake a functional analysis; and how to price intra-group financing transactions. Read more in this PwC alert.
Saudi Arabia: Proposed New Tax Law & Proposed New Zakat and Tax Procedures Law
Zakat, Tax and Customs Authority “ZATCA” recently introduced a proposed almost brand new comprehensive Tax Law and Zakat & Tax Procedures Law for public consultation until 25 December 2023. The objective of the project is to develop and update the current tax law to be in line with the international best practices, considering the best practices in the pioneering G20 countries, as well as the other pioneering countries. Read more in this PwC alert.
Myanmar
Financial sanctions against Myanmar
HM Treasury has recently published a further financial sanctions notice against Myanmar.You can view it on this HMRC page.
Netherlands
FX result on participation dividend receivable taxable
A dividend receivable arises at the moment the company's competent body adopts the dividend resolution. At that moment, the parent company must value the dividend receivable and recognise it as an asset on its tax balance sheet. The dividend to be received by the parent company is exempt if the participation exemption applies. Any results in respect of the dividend receivable (including foreign exchange results) are not covered by the participation exemption and are subject to corporate income tax. The Supreme Court confirmed this in a judgement dated 3 November 2023. Read more in this PwC news item.
Pakistan
Global Forum publishes eight new peer review reports on transparency and exchange of information on request
The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) has published new peer review reports on transparency and exchange of information on request (EOIR) for six of its members (Latvia, Mauritania, Pakistan, Poland, Serbia and Thailand), and supplementary reports that reflect progress made by two members (Botswana and Dominica) in implementing the EOIR standard. Read more in this OECD news item.
Philippines
The Philippines joins the Inclusive Framework on BEPS
The Philippines has joined international efforts against tax avoidance by joining the OECD/G20 Inclusive Framework on BEPS, an international collaboration with over 140 member countries and jurisdictions. Through its membership, the Philippines has also committed to addressing the tax challenges arising from the digitalisation of the economy by participating in the Two-Pillar Solution to reform the international taxation rules. Read more in this OECD item.
Poland
Global Forum publishes eight new peer review reports on transparency and exchange of information on request
The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) has published new peer review reports on transparency and exchange of information on request (EOIR) for six of its members (Latvia, Mauritania, Pakistan, Poland, Serbia and Thailand), and supplementary reports that reflect progress made by two members (Botswana and Dominica) in implementing the EOIR standard. Read more in this OECD news item.
Russia
Financial sanctions against Russia
HM Treasury has recently published further financial sanctions notices against Russia.You can view them on this HMRC page.
Serbia
Global Forum publishes eight new peer review reports on transparency and exchange of information on request
The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) has published new peer review reports on transparency and exchange of information on request (EOIR) for six of its members (Latvia, Mauritania, Pakistan, Poland, Serbia and Thailand), and supplementary reports that reflect progress made by two members (Botswana and Dominica) in implementing the EOIR standard. Read more in this OECD news item.
Singapore
Singapore Inland Revenue updates Corporate Tax Guides
The Inland Revenue Authority of Singapore has issued updates to three e-tax corporate income tax guides: 1) A second edition of Income Tax: Taxation of Insurers Arising from the Adoption of FRS117; 2) A fourth edition of Income Tax: Income Tax Treatment Arising from Adoption of FRS 109 – Financial Instruments; and 3) A fourth edition of Income Tax: Tax Deduction for Borrowing Costs Other Than Interest Expenses.
Singapore and Cambodia sign second protocol to amend their double tax treaty
A Second Protocol amending the Agreement between the Republic of Singapore and the Kingdom of Cambodia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (‘double tax treaty’) was signed on 2 November 2023. The Second Protocol amends the preamble of the double tax treaty and introduces a new Article 28 (Entitlement of Benefits), to incorporate the internationally agreed Base Erosion Profit Shifting standards for countering treaty abuse, among other technical amendments. Read more in this press release.
Switzerland
For the latest updates on current topics, see this PwC Switzerland Insights page.
Taiwan
Taiwan Tax Update September - October 2023
This edition covers that profit-seeking enterprises can claim double deduction for voluntary top-up salary expense paid to employees on leave due to being diagnosed with COVID-19.
Thailand
Global Forum publishes eight new peer review reports on transparency and exchange of information on request
The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) has published new peer review reports on transparency and exchange of information on request (EOIR) for six of its members (Latvia, Mauritania, Pakistan, Poland, Serbia and Thailand), and supplementary reports that reflect progress made by two members (Botswana and Dominica) in implementing the EOIR standard. Read more in this OECD news item.
US
Treasury releases foreign currency proposed regulations
Treasury and the IRS have released proposed regulations relating to the determination of taxable income or loss and foreign currency gain or loss with respect to a qualified business unit (QBU). The proposed regulations include an election to treat all items of a QBU as marked items (subject to a loss suspension rule), an election to recognize all foreign currency gain or loss with respect to a QBU on an annual basis, and a new transition rule. The proposed regulations are scheduled for publication in the Federal Register on 14 November. Public Comments are due within 90 days of publication in the Federal Register. Read more in this PwC Tax Insights.
On notice: US developments and Moore hype
In this Cross-border Tax Talks episode from 30 October, Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Tax Leadership Conference in breezy Orlando with Pat Brown, (co-leader of PwC’s Washington National Tax Services). They discuss US tax updates, including the status and fate of the Tax Cuts and Jobs Act (TCJA); the future of Section 163(j); notices and guidance from Treasury, including the recent Section 174 notice 2023-63; FTC relief notice, and what to anticipate in the coming months and years with respect to foreign tax creditability; what’s included and what’s not included under the corporate alternative minimum tax (CAMT); Section 367(b) ‘Killer B’ regulations; and the Moore case.
Policy on Demand series
- Will Congress reach agreement by 17 November?
Government funding remains a looming topic in Washington. House Speaker Mike Johnson has proposed extending government funding on a temporary basis to 15 January. In this episode from 6 November, Todd Metcalf and Karl Russo share their insights on the potential impact on the likelihood of a year-end tax package. - C-Suite involvement key for path to tax bill
Newly elected House Speaker Mike Johnson has proposed a legislative agenda for the remainder of the current Congress that includes passing a continuing resolution (CR) to fund the federal government through next January or April. In this episode from 30 October, Chairman Dave Camp and Janice Mays discuss what this means for tax policy and a year-end tax package. - Week in Review
- 10 November - A government shutdown will happen if Congress fails to act by 17 November. The uncertainty in resolving government funding issues adds another barrier to action on a year-end tax package. Focus on how Congressional leadership manages the current impasse on government funding and public comments by tax committee leaders on a potential tax package. Watch here.
- 3 November - It is too early to tell whether House and Senate tax writers can agree on a tax package that can ride on a 17 November continuing resolution, but now is the time for the C-Suite to reach out to Congress about the importance of extending key TCJA provisions. Watch here.
Tax Readiness webcast series
- Tax Readiness: Don't leave value on the table - Elevating your compliance function
As new technologies emerge and reporting expands globally, businesses need to continue to update and develop their technology systems to keep pace with the ever-increasing demands. A connected data strategy is the foundation for a streamlined compliance process and opens the door to opportunities in transformation, ERP integration and increased global coordination. Watch the replay here where our panel of specialists on 7 November discussed how businesses can embrace an updated data strategy to help manage reporting and compliance while building value outside of the tax department. - Tax Readiness: What taxpayers need to know about the recent Section 174 and CAMT guidance
In recent weeks, Treasury and the IRS have released critical guidance in two notices that propose rules potentially affecting a vast array of taxpayers - Section 174 guidance and new corporate alternative minimum tax (CAMT) guidance. In this webcast from 9 October, our panellists share their insights from these notices and how businesses should consider responding. Watch the replay here. - Tax Readiness: Insights from the new digital asset reporting regulations
Treasury and the IRS released much anticipated proposed regulations regarding information reporting for Digital Assets. Watch the replay here from our webcast on 5 October where our specialists discuss the scope of these regulations, required obligations, and what steps impacted taxpayers should be taking now in order to prepare. The panel shares policy insights, industry perspective, as well as practical solutions for companies currently involved or looking to be involved in this fast emerging industry.
State and Local tax
- California court rules that single-sales factor initiative survives constitutional challenge
The California Court of Appeal recently concluded that Proposition 39 - which eliminated the three-factor apportionment option and imposed a mandatory single-sales factor apportionment formula - does not violate the state’s constitutional single-subject rule for ballot initiatives. Thus, the taxpayer, an out-of-state corporation, could not utilise a three-factor formula when apportioning its income to California. Read more in this PwC Tax Insights. - Michigan Tax Tribunal holds subsidiary not a member of owner’s unitary business
For tax years 2013-2016, TTI, Inc. (TTI) asserted that its wholly owned subsidiary, Mouser Electronics (Mouser), was not a member of its Michigan Corporate Income Tax Unitary Business Group (UBG). The Michigan Tax Tribunal (Tribunal) recently agreed the entities were not part of the same UBG, finding that TTI and Mouser did not have business activities or operations resulting in a flow of value between them or business activities or operations that are integrated with, are dependent upon, or contribute to each other. Read more in this PwC Tax Insights.
Further information
You can sign up for Tax Alerts issued by the US to be emailed to you. Subscribe using the link on this page. A back catalogue of previous webcasts and other resources are available on our US tax reform hub here.