International Tax
Cross-border structuring, treaties, permanent establishment, management and control, CFC, hybrid mismatch and inbound / outbound investment.
M&A and CFC: The tax Risk that often appears only after completion
July 2, 2026
After Pillar Two and ICTS: HMRC’s 23 June 2026 GIR update confirms that tax governance is now an execution risk
June 24, 2026
After Pillar Two: why the UK’s new ICTS will make transfer pricing a board-level data governance issue
June 19, 2026
Is your knowledge of beneficial ownership, treaty risk and the MLI fully up to date?
June 18, 2026
Foreign Life Insurance Policies and Offshore Bonds: a hidden UK Tax Risk for Internationally Mobile Individuals
June 8, 2026
Pillar Two and M&A: the tax risk now sitting inside the deal
June 3, 2026
UK Tax Residence and exceptional circumstances: what a Taxpayer v HMRC means for International Individuals
May 26, 2026
When a Tax Treaty Is Not a Loophole: What Burlington Means for Cross-Border Groups and Investors
May 18, 2026
Management charges between UK, Italy and UAE: when cost recharges become a transfer pricing problem
May 6, 2026
READY TO TAKE THE NEXT STEP?
Clearer Perspectives on Complex Tax
Technical commentary is only the starting point. Whether navigating complex HMRC enquiries or structuring international investments, Angelo Chirulli provides the high-level technical depth and strategic clarity required to deliver robust tax solutions.