CROSS-BORDER

Matthew Fleming and Chris Leigh (KPMG) examine the legal developments that strengthen HMRC’s ability to tackle cross-border non-compliance. 

An adviser explains the EU proposed cross-border B2B VAT rules to Peckham’s most famous resident. David Rudling (LexisNexis) listens in.

 

Philippe Gamito and Irina Maslova (KPMG) review an advocate general’s opinion which adds significant complexity to VAT recovery by a branch supporting its foreign head office.

 

Eloise Walker and James Tryfonos (Pinsent Masons) provide a guide to the potential tax pitfalls in respect of interest rate swaps.

 

Hatice Ismail, Martin Shah and Gary Barnett (Simmons & Simmons) review the EC’s proposal for a directive to impose mandatory reporting obligations on intermediaries and taxpayers involved in certain cross-border tax planning arrangements.

 

Nigel Barker, Annis Lampard and Jenny Tevlin (Deloitte) examine what Schedule 36 powers mean in practice, and unwrap the latest trends in HMRC analytics.

 

Donald L Korb and Andrew Solomon (Sullivan & Cromwell) review the challenges facing the Trump administration’s efforts to enact a comprehensive overhaul of the US tax code.

 

 

Simon Whitehead and Peter Stewart (Joseph Hage Aaronson) review the recent decision in Six Continents, which considers what foreign profits should receive credit at the foreign nominal rate following an earlier ruling of the CJEU in the FII group litigation.

 

BEPS Action 14 sets out the principles for resolving international tax disputes in the future. The International Chamber of Commerce will be contributing to this debate at an OECD level. Ian Hyde (Pinsent Masons) and Robert Thomas (chair of the UK tax committee of the International Chamber of Commerce) share the findings of a recent ICC UK survey, which reveals strong support for introducing a mandatory binding arbitration and for greater taxpayer involvement in the arbitration process.