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.
Emma Hardwick considers the point during sale negotiations at which a target may lose the ability to surrender or receive group relief
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
Mark Middleditch takes over the reins of our popular monthly briefing on developments affecting the City.
There have been two conflicting tribunal decisions on the recovery of overpaid VAT where a company either later joined or left a VAT group. Nick Skerrett and Gary Barnett analyse the decisions in Standard Chartered and MG Rover Group
After 11 years of litigation, the Supreme Court has held that a claimant can make successive claims for cross-border group relief as long as they are not time barred. Simon Whitehead and Rachel Garwood review the decision and examine the implications
Nigel Doran examines the unorthodox contract settlement in the Ardagh case, and the lessons for advisers.
Chris Morgan reviews recent international tax developments
Jonathan Legg on the Court of Appeal’s reversal of the decision by the Upper Tribunal