OECD

The definition of ‘related’ in the hybrid rules is extremely broad. Dan Neidle and Jemma Dick (Clifford Chance) explain how this could potentially cause companies to be denied interest deductions on ordinary commercial loans.

 

Philip Greenfield (PwC) reports on the extent to which countries have started to adopt the BEPS recommendations. 

 

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.

 

The BEPS limitation on benefits article would hinder cross-border investment. Dan Neidle and Jemma Dick (Clifford Chance) consider why it’s likely to be of limited application.

 

Maya Forstater (Centre for Global Development) asks whether 2017 will be the year that they come together.

 

Tim Sarson (KPMG) reviews the latest developments in the international tax world.

 

Tim Sarson (KPMG) reviews the latest developments in the international tax world.

 

Matthew D Saronson and Ceinwen Rees (Debevoise & Plimpton) examine the application of new anti-treaty abuse provisions to private equity fund structures.