The European Commission has concluded, following an investigation begun in September 2016, that two tax rulings by the Luxembourg authorities in favour of companies in the Engie group (formerly GDF Suez) resulted in illegal state aid amounting to €120m.
The OECD has incorporated new guidance on hard-to-value intangibles (BEPS action 8) and the transactional profit split method (BEPS action 10) into its main transfer pricing guidelines. The OECD consulted on discussion drafts of the guidance in May/June 2017.
Interest on foreign loan
The European Commission has published the letter containing its detailed decision to approve the UK’s application to extend the enterprise management incentive (EMI) scheme. The Commission gave its approval on 15 May.
The government of the British Virgin Islands has announced a legal challenge to the provision in the Sanctions and Anti-Money Laundering Act 2018 obliging the UK government to impose publicly accessible registers of beneficial ownership on any British overseas territory failing to introduce such
The new Protocol to the UK/Uzbekistan double taxation convention, signed in January 2018, entered into force on 1 June 2018 (see https://bit.ly/2Jwhh3n).
In the UK, this is effective:
Liberia signed the OECD’s ‘Multilateral convention on mutual administrative assistance in tax matters’ on 11 June. In May, China extended the territorial scope of the convention to the Hong Kong and Macau special administrative regions, where it will enter into force on 1 September 2018.
As part of the EU budget for 2021 to 2027, the European Commission has published legislative proposals for a budget of €950m for the EU customs programme (up from €523m) and €270m for the Fiscalis programme (up from €223m), to upgrade IT systems and improve cooperation against tax fraud, evasion
ECOFIN has adopted amendments to the administrative cooperation directive, introducing new disclosure and reporting rules for tax intermediaries involved in designing and promoting aggressive cross-border tax planning schemes.