This month's international briefing by Chris Morgan focuses on US FATCA developments and a recent opinion of the Advocate General which challenges the conclusions of the court in Marks & Spencer.
HM Treasury issued a joint statement announcing publication of the Model Intergovernmental Agreement to Improve Tax Compliance and to Implement FATCA.
Confidentiality of taxpayer information ‘has always been a fundamental cornerstone of tax systems,’ says OECD
The OECD has updated Article 26 of the OECD Model Tax Convention explicitly to allow tax authorities to request information on a group of taxpayers without naming them individually.
Carl Mellor provides an overview of issues to consider, with further insight (below) from Peter Cussons and Graham Williams.
Peter Cussons examines the impact of the decision.
Chris Morgan provides your monthly review, including coverage of the decisions in Santander and Philips and Australia's Federal Budget.
Tax campaigner Richard Murphy’s estimate of the UK’s tax gap is ‘misleadingly high’, HMRC has said in a submission to the House of Commons Treasury Committee.
A new double taxation agreement between the UK and Barbados was signed on 26 April.
Senior tax officials from OECD countries met in Montreal to discuss recent ‘unintended double non-taxation’ due to the use of hybrid mismatch arrangements.