At home the CFC and patent box legislation in the Finance Bill has now been agreed by the Committee with a number of amendments made to the former, some potentially important new HMRC guidance on beneficial ownership in relation to double tax treaty claims has been published and the Supreme Court issued its decision in the FII GLO. One of the most significant developments overseas has been the publication of proposals in the Netherlands that could limit interest deduction on loans in relation to subsidiaries that qualify for the Dutch participation exemption, so-called ‘Bosal interest’.
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