The European Commission’s Anti-Tax Avoidance Directive shows that the Commission clearly doesn’t trust member states of the EU to implement the OECD’s BEPS 2015 recommendations, write Zoe Wyatt & Tom Wesel (Milestone International Tax Partners).
A non-confidential version of the Commission’s ‘McDonald’s’ decision has been published, reports Pierre-Régis Dukmedjian & Alejandro Dominguez (Simmons & Simmons Luxembourg LLP).
Gary Richards considers the relevance of IR35 in the light of the recent Office of Tax Simplification’s reports on small company tax and closer alignment of tax and NICs.
Michael Thomas (Pump Court Tax Chambers) looks at the rules introduced in the recent Budget intended to ensure that profits from a trade dealing in or developing UK land are always chargeable to UK corporation tax or income tax.
HMRC raised an additional £489m in corporation tax through investigations into SMEs in 2014/15, according to UHY Hacker Young. Between 2012/13 and 2013/14, SMEs’ share of the corporation tax gap as a proportion of corporation tax liabilities shrank from £2.1bn (11%) to £1.4bn (7%).
HMRC is consulting until 30 June 2016 on the draft Corporation Tax (Treatment of Unrelieved Surplus ACT) (Amendment) Regulations 2016, which make consequential amendments to the shadow ACT rules, to reflect the abolition of the dividend tax credit and the repeal of the term ‘franked investment in
Legislation in Finance Bill 2016 (clauses 33–35) amends the transactions in securities rules and introduces a new targeted anti-avoidance rule in connection with company distributions.