International briefing for June 2012

Over the past month one of the most significant developments overseas has been the publication of proposals in the Netherlands that could limit interest deduction on loans in relation to subsidiaries that qualify for the Dutch participation exemption so called ‘Bosal interest’. I have discussed before how many tax authorities around the world have been increasing tax revenues not by increasing tax rates but by broadening the tax base and this is another clear example of this emerging theme.

Back at home there has been some very quietly announced but potentially quite important new HMRC guidance on beneficial ownership in relation to double tax treaty claims. It suggests that HMRC is intending to toughen its internal practices for new treaty claims and may start to challenge...