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.
Allan Cinnamon reviews the latest tax treaty developments this month, including BEPS Action 6; amendments to the US Model Tax Treaty; diverted profits in Australia; PE profit allocations; a Swiss Supreme court decision on beneficial ownership of dividends; and treaty provisions relating to PEs, equipment leasing and hybrids.
Sean McGinness (The VAT Consultancy) answers a query on VAT on cross-border business establishments
Allan Cinnamon provides an update on tax treaty developments
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.
Martin Zetter (Macfarlanes) summarises recent developments, including the latest from the OECD’s BEPS project, as well as updates from the UK, Spain, the US and Singapore
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
In the first of a new series, Allan Cinnamon provides a global review of tax treaty developments, including the UK’s DPT.
Recent media reports about the London mayor’s tax affairs shine a light on the taxation of US citizens living abroad. David Treitel (American Tax Returns Ltd) explains.
The CJEU has held that reverse charge VAT is due where an overseas entity recharges costs to a branch registered within a VAT group, in a decision that sits uncomfortably with the principle in FCE Bank. Nick Skerrett and Gary Barnett (Simmons & Simmons) consider the implications.