OUR PICK
According to HMRC statistics released last week, HMRC recovered £1.1bn tax from transfer pricing enquiries during 2013/14, which HMRC said was double the tax take of the previous year.
The government announced a new exemption for withholding tax on private placements – a potentially important source of non-bank funding for UK businesses – at the Autumn Statement. James Hume (Slaughter and May) reports.
Heather Self considers the changes made to the Model Tax Convention (MTC) and what these updates mean in practice.
For any transaction involving bonds or notes, there are a number of potential difficulties that may arise, which may include issues involving stamp taxes, VAT, withholding tax, FATCA, and the tax treatment of the bond issuer and bondholders. Eloise Walker and Abigail McGregor provide a handy practice guide for advisers
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
Coming on the heels of Perrin, the decision in Ardmore deals with the meaning of UK source interest. Frixos Hatjantonas reviews
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.
Proposed changes to the taxation of limited liability partnerships (LLPs), due to come into force from April, should be delayed until 2015 to allow business to adapt to the changes, the House of Lords Economic Affairs Committee's Finance Bill Sub-Committee (FBSC) has recommended in its
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.