International briefing for April 2016

It has been a relatively quiet month for the OECD base erosion and profit shifting (BEPS) project with the most notable output being a consultation document on the tax treaty entitlement of non-CIV (collective investment vehicle) funds on 24 March.

 

This month also saw the publication just before the Easter weekend of the UK Finance Bill which contained some international tax legislation. As anticipated the Bill includes updated legislation to amend the UK patent box rules to comply with the OECD BEPS proposals. There are a number of changes since the draft legislation was issued in December including transitional rules dealing with ‘grandfathered’ products that include both existing and new intellectual property (IP) and that increase the ‘nexus’ or ‘R&D fraction’ in exceptional circumstances. Changes have...