International briefing for January 2016

The European Commission has concluded that the Belgian so-called ‘excess profit’ tax rulings system breaches state aid rules. It has also set out its working programme for 2016 on corporate tax, including a new anti-tax avoidance package that will go beyond the OECD recommendations on BEPS, to be presented on 27 January. There has been further progress on ‘corporate tax reform III’ in Switzerland; France has changed its legislation on intragroup dividends following the Groupe Steria case; and Australia’s version of a diverted profits tax regime has now been passed by parliament. In the UK, HMRC has updated its view on company residence for a number of treaties.