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CORPORATE TAXES


Karen Killington and Philippe Gamito (KPMG) consider the implications of the advocate general’s opinion in DNB Banka and Aviva, both for the UK and across the EU.
 
Heather Self (Pinsent Masons) examines the FTT decision where a UK corporate taxpayer succeeded in an argument about loan relationships or financial instruments against HMRC.
 
Karen McGrory (BDO) answers a query on the tax issues facing large multinationals when its employees travel internationally within the group.
 
Emma Game and Dominic Robertson (Slaughter and May) consider the principal tax issues that can arise when establishing, operating and unwinding a corporate joint venture.
 
Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent developments affecting the City.
 

A survey of senior in-house tax experts, by Tax Journal in association with FTI Consulting, assesses the initial impact of the OECD’s recommendations on tackling base erosion and profit shifting.

The UK is pushing ahead with an interest barrier, following BEPS Action 4. Helen Lethaby and Helen Gunson (Freshfields Bruckhaus Deringer) examine the new UK rules which include some nasty tweaks to the OECD recommendations.
 
Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent tax developments affecting the City.
 

On 6 December, the council of EU finance ministers set out their conclusions on the European Commission’s latest corporate tax reform package, issued on 25 October, which included: a two-step approach to establishing a common consolidated corporate tax base (CCCTB); an improved double taxation di

HMRC has published draft guidance on the application of the hybrid mismatch legislation in Finance Act 2016 Sch 10, which takes effect from 1 January 2017. When finalised, this guidance will be incorporated into HMRC’s international manual.

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