Jonathan Bridges (KPMG) examines the key points of the recently announced UK/German proposal for preferential IP regimes
The OECD recently released its discussion draft on the reform of the permanent establishment (PE) rules. Richard Collier (PwC) examines the proposals
As part of the G20/OECD’s work on BEPS in relation to action 10 and transfer pricing of high risk transactions, the discussion draft on the transfer pricing of low value-adding intra-group services has been published. Alison Lobb (Deloitte) reviews the detail
Following the BAA case, HMRC has shifted its position on the recovery of deal fees. In this practice guide, Alan Sinyor (Berwin Leighton Paisner) outlines the key principles of the approach which should now be considered.
Mark Middleditch (Allen & Overy) provides an update of recent developments, including: the announcement of new rules on hybrid mismatches; the high-risk promoters regulations; euro conversion clauses; FATCA; and the EC investigation into the Irish tax rulings over Apple
Does the perfect in-house tax team exist, and can it give a commercial advantage? Leading UK tax directors (pictured below, clockwise from top left) Ian Brimicombe (AstraZeneca plc), Samar Farooq (Care UK), Glyn Fullelove (Informa plc), Paul Morton (Reed Elsevier Group plc) and Jennie Rimmer (Aspen Group) consider the question, as Helen Blenkinsop reports
The ‘tax gap’ figures for 2012/13 showed that illegal activity costs the UK almost five times as much as tax avoidance. When it comes to reducing tax avoidance, argues Tony Beare (Slaughter and May), adverse publicity and the desire to maintain a good working relationship with HMRC are the most powerful drivers.
In this month’s briefing, Lee Squires and Fiona Bantock (Hogan Lovells) take a look at three recent VAT cases: Westinsure Group, Welmory and Huddersfield University; and the HMRC briefing regarding the Lok’nStore Group decision.
Michael Thomas (Gray’s Inn Tax Chambers) reviews the lessons from recent case law.
When will interest rates go up? Certainly not before the end of this year, and possibly not before the end of 2015, as the Bank of England finds reasons to delay, explains David Smith