As a hard Brexit is announced, financial services welcome the confirmation of a phased process of implementation. The European Commission gets to the heart of the Luxembourg tax rules in its ongoing investigation into state aid in favour of GDF Suez. Non-tax changes to partnerships are proposed, although the response to the 2016 consultation on tax changes has yet to be published. Revised draft legislation was published on 26 January on the corporate interest restriction and on carried-forward losses. The UK’s draft Hybrids Guidance illustrates the ways in which the UK legislation goes further than the OECD recommendations.
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