International briefing for June 2016

It has been a busy month for HMRC with a flurry of activity before the start of ‘purdah’ in the lead up to the EU referendum. As well as consultations on corporate tax losses and the substantial shareholding exemption there was also a proposal for the possible introduction of a secondary adjustment rule into the UK’s domestic transfer pricing legislation and a consultation on renewing and extending the scope of the double taxation treaty passport scheme. Draft statutory instruments (SIs) have also been published which relate to the UK’s tax treaties with Jersey Guernsey and the Isle of Man. These SIs introduce the transactions in land anti-avoidance provisions that were announced at Budget 2016 to ensure that non-UK based property developers in those jurisdictions pay the same level of tax as UK-based...