Foreign subsidiaries and loss relief
Secondary liabilities can present a significant concealed tax risk for a purchaser when acquiring a UK corporate target. Due to the wide reach of the provisions, a diligence review of target entities alone will often not identify all the potential tax risks. Mark Boyle and Joe Grehan (EY) provide this practice guide on steps to take to mitigate these risks
Jeanette Zaman and Emma Game (Slaughter and May) consider whether the conditions for demergers to qualify as exempt distributions are in need of an overhaul
Heather Self (Pinsent Masons) asks if this the end for the ‘double Irish’ structure
The Irish finance minister, Michael Noonan, announced in his Budget statement on 14 October that the government is putting a stop to ‘double Irish’ corporate tax avoidance arrangements – such as those utilised by multinational corporations Apple and Google – by requiring all companies registered
Two of the BEPS deliverables that the OECD issued on 16 September indicate transfer pricing changes. These relate to intangibles and documentation. Martin Zetter (Macfarlanes) takes a look.
Free movement of capital and the taxation of foreign holdings
With recent events suggesting an increased interest from the EC in fiscal state aid, taxpayers would benefit from an early awareness of state aid risks, and advisers should also be careful to advise fully on these. Kelly Stricklin-Coutinho (Thirty Nine Essex Street) reports
In a speech to the Securities Industry Conference on 3 October, financial secretary to the Treasury David Gauke MP rejected criticism in international circles that the UK’s patent box facilitates profit shifting.
The government has confirmed it will publish a consultation document at the Autumn Statement later this year on new measures to prevent multinational companies exploiting differences between countries’ tax rules through the use of ‘hybrid mismatch’ arrangements.