Mark Middleditch (Allen & Overy) reviews recent tax developments affecting the City, including UK FATCA rules in relation to holding and treasury companies; a FTT case on the assumption of debt on share sales; BEPS and the US proposals to combat treaty abuse; and the EU Commission’s action plan in relation to the new tax transparency package.
The Times reported (10 June) that the chancellor is poised to axe £3.5bn bank ‘as he tries to head off a decision by Britain’s largest lender to move its headquarters overseas.’ The newspaper reported that the announcement is due to be made at the annual Mansion House speech on Wednesday
The value of the retail price index for April 2015 is 258.0. The new table shows the indexation factors to be used in calculating the indexation allowance for corporation tax purposes in respect of assets disposed of in April 2015.
‘Repos’ and the loan relationship rules
Amazon is now booking sales through a number of branches in Europe. Jonathan Cooklin and David Wilson (Davis Polk) consider what led to the change and the likely impact.
The European Commission has agreed to relaunch work on establishing a common consolidated corporate tax base (CCCTB) for EU member states, as part of the tax transparency action plan to be launched later this month.
HMRC has published a tax information and impact note on amendments to the worldwide debt cap provisions, following the implementation of the new UK GAAP, to ensure changes to accounting standards do not create unintended additional corporation tax liabilities.
HMRC is unable to answer FOI request on the Lagarde list, writes John Barnett (Burges Salmon).
Chris Morgan (KPMG) provides a review of recent international tax developments that matter.