HMRC has published draft guidance on one of the CFC changes in the Finance Bill. The CJEU has rejected the UK government’s legal challenge to the proposed financial transaction tax on procedural grounds and the political will to proceed with this initiative is continuing. The EC’s proposed amendment to the EU Parent-Subsidiary Directive in relation to hybrid loans has been blocked by Sweden, but discussions are continuing with a view to obtaining agreement shortly. A recent case in India highlights the risk of creating a permanent establishment when sending employees to India on secondment. Draft guidance on the German corporate tax loss limitation rules has been published.
