Application of VAT exemption on supplies of imported good
The European Parliament voted on 12 February to set up a special parliamentary committee to look into EU member states’ ‘tax rulings and other measures similar in nature or effect’ and make recommendations for the future.
The CJEU judgment in European Commission v UK has rejected a challenge to the UK group relief legislation, following on from the Marks and Spencer litigation. Rupert Shiers (Hogan Lovells) reviews the decision and asks where this leaves us.
In the first of a new series, Allan Cinnamon provides a global review of tax treaty developments, including the UK’s DPT.
Bilateral investment treaties, which protect and promote cross-border investments, are one of many areas of law which may be relevant for tax lawyers. Timothy Lyons QC and Kelly Stricklin-Coutinho (Thirty Nine Essex Street) explain why
What can we expect from the forthcoming changes to the taxation of hybrid financial instruments, ask David Harkness and David McCann (Clifford Chance)
Non-resident close companies and free movement of capital
Germany and the UK have agreed a compromise proposal on patent box regimes. The agreement is based on the OECD's modified nexus approach requiring tax benefits to be connected directly to R&D expenditures, but seeks to address concerns with revised elements, including:
Peter Cussons (PwC) considers whether AG Kokott’s opinion, which urged the CJEU to reverse its decision in Marks & Spencer, will spell the end for cross-border loss relief
Richard Woolich (DLA Piper) points out ten practical points to understand in relation to the new regime for all businesses when managing their cross-border supplies, both B2B and B2C