Mark Middleditch (Allen & Overy) reviews recent tax developments affecting the City, including UK FATCA rules in relation to holding and treasury companies; a FTT case on the assumption of debt on share sales; BEPS and the US proposals to combat treaty abuse; and the EU Commission’s action plan in relation to the new tax transparency package.
guidance on practical aspects arising from the removal of holding and treasury companies from the definition of ‘financial institution’ (FI) which applies for the purposes of the UK FATCA rules (see The International Tax Compliance Regulations SI 2015/878).
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