COMPLIANCE

With even more information at the Commission’s disposal from January next year, it seems inevitable that more fiscal state aid investigations are to come. Liesl Fichardt (Clifford Chance) looks at the Commission’s potential future targets.

Michael Lebovitz

The EU’s ‘overreach’ on state aid has rankled the US tax authority, as Michael Lebovitz (White & Case) reports.

HMRC has confirmed it is offering an extended self-assessment filing deadline for severe weather.

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

Santhie Goundar

HMRC has revised its interpretation of the residence articles in 16 double taxation agreements, taking the view that a tie-breaker clause should be used to decide a company’s residence. Previously, HMRC regarded dual-resident companies as outside the scope of the treaties.

Cathya Djanogly

Unsuccessful loan relationship avoidance scheme

Peter Kiernan

Manraj Somal

Following HMRC’s recent consultation paper and proposed response document and draft legislation ahead of the Autumn Statement, Peter Kiernan and Manraj Somal (KPMG) answer questions on plans to make corporations criminally liable for tax evasion.

Tim Law

TAXE Committee gives multinationals ‘one more chance’ to turn up, reports Tim Law (Engaged Consulting)

Peter Jackson

Peter Jackson (Taylor Wessing) examines the tax issues surrounding a UK REIT group which wishes to purchase shares in a UK resident and a non-UK resident SPV.

Tim Law

Tim Law (Engaged Consulting) takes a look at the consultation document on improving large business tax compliance, and the three proposed measures contained therein.

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