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
Advocate General Kokott’s opinion has been published on the European Commission’s action against the UK for failing to properly implement the decision in the Marks & Spencer cross-border group relief case.
In a development proclaimed by its organisers as ‘a huge breakthrough’, SSE plc became the first FTSE 100 company to be awarded the Fair Tax Mark – a ‘kite mark’ awarded to companies considered to be ‘open and transparent about their tax affairs and seek to pay the right amount of corporation tax