New EU proposals will mean yet more country by country reporting for multinationals to improve levels of public scrutiny. The OECD continues its consultations on the treatment of certain funds under BEPS proposals for anti-treaty abuse. HMRC publishes guidance for large businesses on new rules in the Finance Bill requiring publication of tax strategies, and special measures for the ‘persistently uncooperative’. As many had hoped, the Upper Tribunal finds that bonds with euro conversion clauses are not QCBs after all.
