Mark Middleditch (Allen & Overy) examines the themes that have dominated 2016 for the City, including the anti-hybrid rules brought on by the UK’s enthusiasm for BEPS, and looks at 2016’s case law, which shows that HMRC continues its run of success in defeating tax avoidance schemes.
Ashley Greenbank (Macfarlanes) considers the proposals for the introduction of further adjustments to counteract the financial benefits of cash flows arising from non-arm’s length transfer pricing.
The European Commission’s Anti-Tax Avoidance Directive shows that the Commission clearly doesn’t trust member states of the EU to implement the OECD’s BEPS 2015 recommendations, write Zoe Wyatt & Tom Wesel (Milestone International Tax Partners).
A non-confidential version of the Commission’s ‘McDonald’s’ decision has been published, reports Pierre-Régis Dukmedjian & Alejandro Dominguez (Simmons & Simmons Luxembourg LLP).
Thomas Dalby (Gabelle) answers a query on a UK tech company that is being purchased by a US company which has offered to settle its unexercised EMI options in cash.
The European Commission has concluded that selective tax advantages granted by Belgium under its ‘excess profit’ tax scheme are illegal under EU state aid rules.
Finance (No.2) Act 2015 introduced a surcharge of 8% on the taxable profits of banking companies arising on or after 1 January 2016.
The Dutch ministry of finance has issued a statement confirming that the Netherlands will be appealing the European Commission’s ruling in October that the country provided state aid to Starbucks Manufacturing EMEA BV.