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
Chris Morgan (KPMG) provides an update on recent international developments, including: the CJEU’s release of the AG opinion on the UK rules on cross-border group relief following Marks & Spencer; EU finance ministers’ agreement on an extended information exchange mechanism; Ireland’s 2015 Budget announcement on the ‘double Irish’ tax structure; corporation tax reform III in Switzerland; and the Centrica case in India.
Advocate General Kokott’s opinion has been published on the European Commission’s action against the UK for failing to properly implement the decision in the Marks & Spencer cross-border group relief case.
Mark Agnew and Arianne Wijdeveld (Baker & McKenzie) consider the impact that the Skandia decision will have for financial services groups in the UK.
Free movement of capital and the taxation of foreign holdings
The government has confirmed it will publish a consultation document at the Autumn Statement later this year on new measures to prevent multinational companies exploiting differences between countries’ tax rules through the use of ‘hybrid mismatch’ arrangements.
Chris Lallemand (Smith & Williamson) discusses some contrasts between the UK implementing legislation for the UK/US IGA, equivalent US regulations and HMRC’s guidance
Exclusion of tax advantage on cross-border transactions
Heather Self considers the changes made to the Model Tax Convention (MTC) and what these updates mean in practice.