Allan Cinnamon reviews the latest tax treaty developments this month, including BEPS Action 6; amendments to the US Model Tax Treaty; diverted profits in Australia; PE profit allocations; a Swiss Supreme court decision on beneficial ownership of dividends; and treaty provisions relating to PEs, equipment leasing and hybrids.
David Boneham (Deloitte) summarises what the disregard regulations cover, and explains the aspects that companies need to consider when adopting new UK GAAP.
Tax receipts have underperformed in recent years. If that changes, the public finances will start to look healthier. There is tentative evidence of such a change, as David Smith reports.
The Littlewoods litigation continues the victorious advance of claimants seeking redress for the payment of undue VAT, writes Michael Conlon QC (Hogan Lovells).
Philip Gershuny (Hogan Lovells) looks at the potential impact of a UK exit from the EU on the UK tax system.
Zoe Fatchen (Wragge Lawrence Graham & Co) sets out the key features of EIS and SEIS for individuals seeking qualifying commercial investment opportunities and provides some practical tips for advisers.
The government should create two new institutions – a new Office of Tax Policy and a Joint Parliamentary Select Committee on Taxation – to inform its policy making, writes Judith Freedman (Oxford University).
The Upper Tribunal considered the application of lower VAT rates in the Colaingrove case. Alan Sinyor (Berwin Leighton Paisner) considers the broader implications of the decision.
Chris Morgan (KPMG) provides a review of recent international tax developments that matter.
Peter Halford (PwC Legal) considers AG Kokott’s opinion in the ‘Austrian goodwill’ case, including its implications for the Commission’s appeals to the CJEU in the ‘Spanish goodwill’ cases.