Further guidance is published by HMRC on the treatment of holding and treasury companies under the UK’s FATCA rules. The First-tier Tribunal holds that consideration on a share sale can be increased by the amount of a debt assumed by the buyer, and originally owed by the seller to the target. The OECD publishes a revised discussion draft on avoiding treaty abuse, and the US makes its own proposals for amending the US model treaty. The EU Commission gives some further clarity on its tax transparency package, and the relaunch of the common consolidated corporate tax base.
