India and the Philippines have signed FATCA intergovernmental agreements (IGAs) with the US. Both IGAs are based on the model 1A IGA, and both jurisdictions have previously reached agreements in substance for a Model 1A IGA with the US.
Mark Middleditch (Allen & Overy) reviews recent tax developments affecting the City, including UK FATCA rules in relation to holding and treasury companies; a FTT case on the assumption of debt on share sales; BEPS and the US proposals to combat treaty abuse; and the EU Commission’s action plan in relation to the new tax transparency package.
The definition of investment entities under FATCA, under the model IGA and under the UK IGA, regulations, guidance notes varies in important respects. Andrey Krahmal (Temple Tax Chambers) provides a summary of how the rules apply to investment entities most frequently encountered in practice.
FATCA affects the operations of most UK funds. Andrey Krahmal provides a summary