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CJEU


HMRC’s guidance on Skandia is a useful starting point, but still leaves considerable uncertainty on one of the highest profile VAT developments for the financial services industry in recent years, write Gary Campbell and Daniel Johnson (Deloitte).

Christopher Morgan (KPMG) provides an update of recent developments, including: the OECD’s BEPS project; the CJEU decision in the EC’s challenge to UK cross-border relief; the Prudential Assurance case; the EC investigation into Belgium’s excess profit rulings; and news from Ireland and the US.

The CJEU judgment in European Commission v UK has rejected a challenge to the UK group relief legislation, following on from the Marks and Spencer litigation. Rupert Shiers (Hogan Lovells) reviews the decision and asks where this leaves us.

Giles Salmond (Eversheds) provides his perspective on PPG and recent decisions of the CJEU, and looks at where this leaves us

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.

Mark Agnew and Arianne Wijdeveld (Baker & McKenzie) consider the impact that the Skandia decision will have for financial services groups in the UK.

The CJEU has held that reverse charge VAT is due where an overseas entity recharges costs to a branch registered within a VAT group, in a decision that sits uncomfortably with the principle in FCE Bank. Nick Skerrett and Gary Barnett (Simmons & Simmons) consider the implications.

Jonathan Gordon (DLA Piper) examines the implications of the CJEU’s decision in K Oy concerning VAT on e-books

Chris Morgan reviews recent developments in the international arena, including: the cross-border group relief infringement proceedings which the EC has brought against the UK; the amendment to the Parent-Subsidiary Directive; the 2014 Budget in India; corporate tax changes in Japan; and updates from Poland and Sweden on proposed CFC rules and corporate tax reform respectively

Peter Jenkins considers the development of a new threat to input tax recovery by partly exempt businesses receiving subsidies

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