A consultation on tax treaties anti-avoidance could have wider implications than apparently intended based on the draft legislation published. The Upper Tribunal has reversed the decision in the Swift case and has ruled that a US LLC is not transparent for tax purposes. The ECJ has confirmed the AG’s opinion in Scheuten Solar Technology. The ECJ has published its second decision in the Meilicke case. There have been two important recent US developments: publication of a Directive on the Codified Economic Substance Doctrine (the US ‘GAAR’) and the latest version of the Stop Tax Haven Abuse Act.
