Chris Morgan (KPMG) provides a round-up of recent developments, including: recent OECD discussion drafts from the BEPS project; discussions on the introduction of a GAAR into the EU Parent-Subsidiary Directive; the CJEU judgment on TCGA 1992 s 13; and updates from Germany and Chile.
What can we expect from the forthcoming changes to the taxation of hybrid financial instruments, ask David Harkness and David McCann (Clifford Chance)
Richard Collier and Philip Greenfield (PwC) examine the OECD’s first set of recommendations for tackling base erosion and profit shifting (BEPS) - finding few surprises, but no let up.
Organisation calls deliverables a ‘historical achievement on the long road to global tax justice’
Martin Zetter (Macfarlanes) provides an update on the Amazon hearing in the US; plus transfer pricing news from India, Bolivia and Tanzania; and the OECD consultation on BEPS action 11
Tackling BEPS: Donald L. Korb and S. Eric Wang provide a US perspective
Tackling BEPS: Philip Baker QC considers what real success and failure would look like
Tackling BEPS: Chris Sanger examines how some countries are going it alone
Tackling BEPS: Andrew Goodall on current priorities and concerns
The G20/OECD project on measures to tackle base erosion and profit-shifting (BEPS) appears to be on track despite a very ambitious timetable. But the project is still in its early stages, and there are signs that expectations may be running a little too high.