The EC has published the non-confidential version of its decision sent to the Netherlands tax authorities in June to open a formal state aid investigation into corporate tax rulings involving Starbucks.
Belgium is investigating HSBC’s private banking arm – based in Zurich, Switzerland – for tax fraud, including money laundering, criminal organisation and acting as an illegal financial intermediary, according to financial newspaper City AM.
Non-resident close companies and free movement of capital
Mark Middleditch (Allen & Overy) provides an update of recent developments, including: the announcement of new rules on hybrid mismatches; the high-risk promoters regulations; euro conversion clauses; FATCA; and the EC investigation into the Irish tax rulings over Apple
The financial transaction tax inches closer, write Richard Croker and Anna Burchner (CMS Cameron McKenna)
Germany and the UK have agreed a compromise proposal on patent box regimes. The agreement is based on the OECD's modified nexus approach requiring tax benefits to be connected directly to R&D expenditures, but seeks to address concerns with revised elements, including:
The International Consortium of Investigative Journalists (ICIJ) has published leaked documents setting out tax deals that some of the world’s largest multinational corporations struck with Luxembourg.
Deemed interest and FA 2003 s 195
Intra-group acquisition of loan notes and the related party rule
Anthony Newgrosh (BKL) answers a query on when parties are connected under the loan relationship rules