There have been two recent developments on BEPS Action 4 with some, but not all, the draft legislation on the new UK corporate interest restriction published with the draft Finance Bill clauses and an updated version of the OECD Action 4 report released in December. The OECD has also published the long-awaited multilateral instrument. Overseas there have been proposals released on reform of Japan’s CFC regime, legislative changes to the Dutch fiscal unity rules, a CJEU decision on Spain’s goodwill amortisation rules, finalisation of a number of important tax changes in France and the release of a protocol amending the Singapore/India tax treaty.
