Your monthly review of key international tax issues by Chris Morgan, including comment on tax treaties anti-avoidance and the Anson case
The de minimis mismatch, how to identify the group and relevant companies, clearing intercompany loans ... Robert Langston looks at five key issues that arise in practice concerning the debt cap rules
Paul Howard sets out the tax consequences for the different methods of finance
Capital allowances: personal security
Corporate loss carry-forwards are now as high as 25% of GDP in some countries, according to the OECD.
The government should revisit tax assumptions used in assessing the value for money of private finance initiative projects and introduce arrangements for sharing gains on the sale of PFI equity shares, MPs have recommended.
The proposed timescale for mandatory pooling of expenditure on fixtures is ‘much too short’ to ensure that the legislation is properly understood and applied, according to the ICAEW Tax Faculty.
HMRC are to publish an update to last month’s ‘tax treaties anti-avoidance’ consultation in the light of concerns raised by business and tax advisers.