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FOREIGN-INCOME


The proposed corporate offence for failing to prevent tax evasion is now set out in the Criminal Finance Bill, and HMRC has issued revised draft guidance. Jason Collins and Tori Magill (Pinsent Masons) outline the ways a relevant body can manage their exposure to risk.

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.
 

President Obama has proposed a levy for US corporations on profits located abroad, which are not repatriated to the US. Kristin Konschnik and Mitchell R. Kops (Withers) consider the proposals and what effect they may have in practice

Karen Bowen, a tax director at Francis Clark, answers questions on HMRC's recent change in practice.

Sara Luder (Slaughter and May) explains why politicians should think carefully about the consequences of proposed tax changes

Go directly to jail; do not pass ‘go’; do not collect £200. Is HMRC’s approach  getting out of hand, asks Peter Vaines, partner, Squire Patton Boggs

Chris Morgan reviews recent developments in the international arena, including Italy’s ‘Google tax’, the Swiss government’s report on ‘corporate tax reform III’ and Austria’s group tax proposals

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