The key development in the BEPS project this month is the publication of further guidance from the OECD on the implementation of the incoming country by country reporting requirements. The CJEU did not follow the AG’s opinion, but has dismissed the EC’s proceedings against the UK cross-border group relief provisions. A further judgment has been given by the High Court in the Prudential Assurance case on the taxation of portfolio dividends. The EC continues its investigations into tax rulings, this time focusing on Belgium’s excess profit rulings. A public consultation on Ireland’s knowledge development box has now been launched. President Obama’s recent Budget recommendations include a one-off tax on previously untaxed foreign income.
