The OECD BEPS 2015 deliverables are expected early next month, so this month’s focus is on developments overseas. The CJEU has concluded that the French participation exemption does not comply with EU law and changes are therefore likely. Two important points have been clarified in India: on management fees under the UK treaty; and the liability to minimum alternative tax of overseas investors. The Australian government is pushing forward with country by country reporting, the New Zealand government has clarified some points on shareholder debt forgiveness/capitalisation, and in Thailand a new international headquarters regime has been introduced.
