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FOREIGN PROFITS


Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) examine possible planning opportunities to safeguard a remittance basis user’s existing clean capital reserves.

Chris Morgan (KPMG) assesses the latest developments that matter in the international tax arena.

Finance (No.2) Act 2015 introduced a surcharge of 8% on the taxable profits of banking companies arising on or after 1 January 2016.

The EC on Monday 14 December confirmed that it has requested more information in its ongoing investigation into whether Irish tax rulings granted to Apple constituted illegal state aid.

The Dutch ministry of finance has issued a statement confirming that the Netherlands will be appealing the European Commission’s ruling in October that the country provided state aid to Starbucks Manufacturing EMEA BV.

Amazon is now booking sales through a number of branches in Europe. Jonathan Cooklin and David Wilson (Davis Polk) consider what led to the change and the likely impact.

HMRC has been quick to publicise its success in a tax case involving Next Brand Ltd, which is part of the Next group, over its use of a tax avoidance structure known as a rate-booster.

The US Internal Revenue Service (IRS) has confirmed, in FAQs, that only direct reporting non-financial foreign entities (NFFEs) are required to submit nil reports for FATCA.

Hey, a new tax. As a tax adviser, that sounds like pretty good news. (Shame it is so bad for the country, but that's politics for you).

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