Multinational tax planning remains in the spotlight with the publication of the OECD’s action plan on base erosion and profit shifting, and the House of Lords Select Committee’s report on tackling corporate avoidance in the global economy. The draft Taxation of Regulatory Capital Securities Regulations confirm the debt treatment for securities that count as additional tier 1 or tier 2 capital in the banking sector; the proposals deal with more issues than might have been expected and are to be welcomed. A number of consultations relevant to the City come to an end this month, and HMRC has won notably victories in two SDLT cases.
