Chris Morgan (KPMG) provides a round-up of recent developments, including: recent OECD discussion drafts from the BEPS project; discussions on the introduction of a GAAR into the EU Parent-Subsidiary Directive; the CJEU judgment on TCGA 1992 s 13; and updates from Germany and Chile.
As has been the case for some time now the OECD’s Action Plan on base erosion and profit shifting (BEPS) continues to dominate headlines. Activity has now moved onto the 2015 deliverables and on 31 October the OECD published a discussion draft on Action 7 titled Preventing the artificial avoidance of PE status which sets out options for a new definition of permanent establishment (PE) under the OECD Model Tax Convention. In total 13 options have been set out potentially resulting in a significant widening of...
