International briefing for October 2015

The OECD published final BEPS proposals on 5 October and attention now moves to how the Actions will be implemented. HMRC has published a Brief setting out its interpretation of the Anson case on US LLCs. At the EU, finance ministers have agreed to introduce rules for the mandatory exchange of information on cross-border tax rulings; proposals for a CCCTB have re-emerged; and the CJEU has issued a decision on deductibility of goodwill amortisation in Austria. Ireland and Norway have both recently had Budgets and in China a new administrative system for granting treaty benefits will soon be launched.