HMRC has revised its interpretation of the residence articles in 16 double taxation agreements, taking the view that a tie-breaker clause should be used to decide a company’s residence. Previously, HMRC regarded dual-resident companies as outside the scope of the treaties.
TAXE Committee gives multinationals ‘one more chance’ to turn up, reports Tim Law (Engaged Consulting)
OECD recommendations hailed as ‘important milestone’, and the challenge now is to ensure measures are implemented consistently and coherently.
Mark Middleditch (Allen & Overy) reviews the latest tax developments that matter affecting the City.
HMRC is consulting until 7 September 2015 on the detail of its proposal to extend the averaging period for farmers’ profits from 2 years to 5 years with effect from April 2016. This follows the government announcing an extension of the averaging period for farmers at Budget 2015.
Barrister Anne Fairpo (Temple Tax Chambers) explains why and how the DPT could apply to real estate transactions.
Amazon is now booking sales through a number of branches in Europe. Jonathan Cooklin and David Wilson (Davis Polk) consider what led to the change and the likely impact.
Cessation of partnership and VAT liabilities
Chris Morgan (KPMG) provides a review of recent international tax developments that matter.
Australia, like the UK, has announced new measures countering the diversion of profits by multinationals, writes Heather Self (Pinsent Masons). The measures increase the pressure on the US to engage with the OECD’s BEPS project.