Chris Morgan reviews recent developments in the international arena, including Italy’s ‘Google tax’, the Swiss government’s report on ‘corporate tax reform III’ and Austria’s group tax proposals
It has been a very quiet period in the UK following the Autumn Statement and publication of draft clauses for Finance Bill 2014 in mid-December unsurprisingly given the Christmas and New Year holidays.
HMRC has published a guidance note looking at the interaction between the finance company exemption in the controlled foreign company (CFC) rules and the loan relationships ‘unallowable purpose’ rule.
However following the tightening of the CFC rules announced at the Autumn Statement the note says very little except to confirm that HMRC will not give non-statutory clearances in relation to the unallowable purpose rules.
My focus this month is mainly overseas and ...
