Chris Morgan (KPMG) provides an update on recent international developments, including: the CJEU’s release of the AG opinion on the UK rules on cross-border group relief following Marks & Spencer; EU finance ministers’ agreement on an extended information exchange mechanism; Ireland’s 2015 Budget announcement on the ‘double Irish’ tax structure; corporation tax reform III in Switzerland; and the Centrica case in India.
Last month saw the release of the 2014 deliverables from the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan which stated that: ‘Jurisdictions can begin to implement recommendations for co-ordinated domestic tax legislation and tax treaty provisions to neutralise hybrid mismatch arrangements.’ The UK government responded very quickly with an announcement on Sunday 5 October that it is intending to publish a consultation on the implementation of the OECD recommendations at...
