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International – Round up of world developments

Speed Read: Following the UK Bank Payroll Tax announced at the PBR there have been similar developments overseas most notably the proposed US 'financial crisis responsibility fee'. The worldwide debt cap rules are now in force but not all HMRC guidance or regulations have been published so many groups are struggling to quantify the impact. The HM Treasury discussion document on the CFC regime has just been published. The French Government has introduced transfer pricing documentation requirements and responded to the ECJ Papillon case on group consolidation. Two ECJ cases are discussed: EU Commission v Italy and the X Holding BV case.
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