Paula Tallon answers a question on corporate partners and loans made to companies.
‘India will delay the introduction of wide-ranging proposed tax avoidance laws by one year, in a move designed to placate international investors worried over increasingly erratic legal changes.
Tax professionals have welcomed new HMRC guidance on the application of the Senior Accounting Officer legislation but have drawn attention to ‘significant changes’ in HMRC’s position, including the end of the ‘light touch’ approach.
The Parliamentary Assembly of the Council of Europe has warned that ‘massive’ offshore tax evasion and avoidance cause ‘serious harm to the public interest’ in Europe and elsewhere, and particularly in developing countries.
Country by country reporting of profits and taxes paid is ‘essential’ for detecting corporate tax avoidance, according to MEPs who adopted by 538 votes to 73 a resolution on ‘concrete ways to combat tax fraud and tax evasion’. There were 32 abstentions.
A common consolidated corporate tax base should be compulsory for all companies except SMEs after a transitional period, according to a resolution of the European Parliament approved last month by 452 votes to 172, with 36 abstentions.
The divide between tax professionals and tax justice campaigners on the issues of transfer pricing and country by country reporting by multinationals was laid bare at a ground-breaking ‘tax and transparency forum’ attended by more than 200 people in London yesterday.
Many company sales entail part of the consideration being satisfied in the form of loan notes issued by the purchaser. Peter Rayney provides practical guidance on the tax issues.
HMRC has indicated it may be changing its view as to the nature of perpetual debt. William Watson and John Meehan consider the ramifications.
David Wilson sets out some key tax issues for advisers to consider this month.