Dominic Robertson (Slaughter and May) reports on the likely changes needed to group structures in light of BEPS, state aid challenges and the diverted profits tax
Hey, a new tax. As a tax adviser, that sounds like pretty good news. (Shame it is so bad for the country, but that's politics for you).
It is clear that the government feels the need to ‘do something’. However, it is much less clear that the diverted profits tax proposals is the best thing to do, as Heather Self (Pinsent Masons) explains.
Which taxpayers should review their position following the CJEU decision in EC v UK regarding TCGA 1992 s 13)? Peter Cussons, international corporate tax partner at PwC, considers the implications for taxpayers and believes further amendments to the legislation could be possible.
Intra-group acquisition of loan notes and the related party rule
Foreign subsidiaries and loss relief
Mark Agnew and Arianne Wijdeveld (Baker & McKenzie) consider the impact that the Skandia decision will have for financial services groups in the UK.
Can the trend for tax inversions survive an assault from the US Treasury department? Adam H Rosenzweig, professor of law at Washington University School of Law, assesses the situation.
Heather Self considers the changes made to the Model Tax Convention (MTC) and what these updates mean in practice.
Peter Mason answers a query on the problems with VAT groups in the case of a US banking client.