International review for June 2019

The OECD’s approach to the challenges of the taxation of the digital economy has now been formalised by a road map agreed upon by the Inclusive Framework. The road map is a significant step forward and seeks to put the OECD on course to reach consensus on solutions to these challenges by the end of 2020 but significant obstacles remain. The UK government has formally applied for an annulment of the European Commission’s decision following the state aid investigation into the CFC group financing exemption. The UK is nonetheless obliged to start the process of recovery from taxpayers. HMRC has released its draft guidance on the offshore receipts from intangible property rules together with proposed regulatory amendments and accompanying explanatory notes. The amendments have unexpectedly widened the scope of certain aspects of the rules and some of the relieving measures do not go as far as taxpayers may have...