The OECD has released public comments on the BEPS discussion draft on action 14 (making dispute resolution mechanisms more effective). See the 413-page document.
Peter Cussons examines the potential EU law and international issues facing the UK's diverted profits tax.
In the first of a new series, Allan Cinnamon provides a global review of tax treaty developments, including the UK’s DPT.
Mark Middleditch (Allen & Overy) provides the monthly round-up of tax developments affecting the City
Richard Collier and Aamer Rafiq (PwC) look at the recent OECD BEPS discussion paper
Dominic Robertson (Slaughter and May) reports on the likely changes needed to group structures in light of BEPS, state aid challenges and the diverted profits tax
William Morris (BIAC) reflects on the lessons learned to date that will contribute to a successful outcome for the BEPS project
A bit of Christmas fun... BEPS metaphors and similes by Colin Garwood.
It is clear that the government feels the need to ‘do something’. However, it is much less clear that the diverted profits tax proposals is the best thing to do, as Heather Self (Pinsent Masons) explains.
Traditional treaty principles that allocate taxing rights between residence and source states, which have long formed the cornerstone of international tax consensus, are undergoing rapid re-evaluation, writes Jonathan Schwarz (Temple Tax Chambers)