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International briefing for September 2012

Speed read

There have been further important developments on FATCA this month with the intergovernmental agreement between the US and the UK being signed, and HMRC releasing a consultation document discussing the potential implementing legislation for this agreement. An expert committee in India has published recommendations on their GAAR proposals including, most notably, a suggestion that implementation be delayed for three years. The CJEU has published two important decisions this month: the Philips Electronics case which could have significant implications for UK group relief; and the Commission v Portugal case which confirms the view that elements of the UK’s exit tax rules are unlawful.

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