Free movement of capital and the taxation of foreign holdings
Chris Morgan provides an update of recent key developments, including: the EC state aid investigation into Apple, Starbucks and Fiat; CJEU judgments in two Dutch cases; and updates from Singapore, Sweden and Poland
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
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.
John Watson, former head of tax at Ashurst, with assistance of Martin Precious, reviews the options for reform of the international taxation of corporate profits, in view of the OECD's action plan on tackling base erosion and profit shifting.
Peter Clements and May Smith review the two proposed changes that the European Commission has recently made to the Parent-Subsidiary Directive, following its action plan on tackling base erosion and profit shifting, and what the implications are for the UK and other member states.
Following the OECD meeting in Paris last week, Bill Dodwell and Alison Lobb examine the challenges in implementing country by country reporting and its proposed common template.
Some immediate reaction on the OECD's Action Plan on Base Erosion and Profit Shifting.
James Bullock looks at the activist group's failed attempt to challenge HMRC
HMRC publishes an introduction to the FA 2012 reforms