Jonathan Levy comments on EU proposals to reduce cross-border red tape
The CJEU confirmed that an investment fund with a registered office in the US was entitled to claim an exemption from withholding tax on dividends granted by Poland only to domestic funds. This has implications for EU member states that grant exemptions only to domestic and European funds, writes Philip Baker QC
The monthly round-up by Chris Morgan, with news from the OECD’s BEPS project, two CJEU cases and the latest from France, India and Chile
Martin Zetter and Ashley Greenbank review the OECD’s recent discussion draft on this issue
Colin Garwood, head of group tax at InterContinental Hotels Group, provides an industry view on BEPS related issues and responds to a recent call for a top-up tax.
Our final report on the tax regimes of BRIC countries focuses on Russia: Andrey Duyunov and Petr Popov provide an overview of the country’s tax rules; Santhie Goundar reports on recent changes; and Andrew Terry gives a tax expert’s view on doing business in and with Russia.
The IRS has issued the last substantial package of regulations necessary to implement FATCA.
Chris Morgan reviews recent international tax developments, including updates from Canada, as well as the OECD’s BEPS project and common reporting standard, CJEU judgments on German exit taxes and the Hungarian ‘crisis tax’, and the M&S Supreme Court decision
After 11 years of litigation, the Supreme Court has held that a claimant can make successive claims for cross-border group relief as long as they are not time barred. Simon Whitehead and Rachel Garwood review the decision and examine the implications
In its judgment on the remaining issues in the Marks and Spencer cross-border group relief claim, the Supreme Court has ruled that although the company was in principle allowed to make fresh loss claims, these are now time-barred.