The OECD has published two BEPS discussion drafts as it moves onto the 2015 deliverables: one on permanent establishments and the other on transfer pricing. The UK and Germany have agreed to a proposal on IP which would impact the UK patent box regime. At the EU, progress has been made on changes to the Parent-Subsidiary Directive; and the CJEU has concluded that the old provisions of TCGA 1992 s 13 are contrary to EU law. A new anti-hybrid rule has been proposed in Germany and significant changes to corporate taxation have now been enacted in Chile.
