Chris Morgan reviews recent developments in the international tax sphere, including: the two changes to the CFC exemption contained in FB 2014; a summary of the CJEU’s rejection of the UK’s FTT challenge; proposed amendments to the EU’s Parent-Subsidiary Directive; and updates from India and Germany
For borrowers and lenders subject to FATCA withholding, maintaining FATCA grandfathering on a debt instrument may be critical to avoiding FATCA withholding tax, writes Reed Carey
Jonathan Levy comments on EU proposals to reduce cross-border red tape
The CJEU confirmed that an investment fund with a registered office in the US was entitled to claim an exemption from withholding tax on dividends granted by Poland only to domestic funds. This has implications for EU member states that grant exemptions only to domestic and European funds, writes Philip Baker QC
The monthly round-up by Chris Morgan, with news from the OECD’s BEPS project, two CJEU cases and the latest from France, India and Chile
Martin Zetter and Ashley Greenbank review the OECD’s recent discussion draft on this issue
Colin Garwood, head of group tax at InterContinental Hotels Group, provides an industry view on BEPS related issues and responds to a recent call for a top-up tax.
Our final report on the tax regimes of BRIC countries focuses on Russia: Andrey Duyunov and Petr Popov provide an overview of the country’s tax rules; Santhie Goundar reports on recent changes; and Andrew Terry gives a tax expert’s view on doing business in and with Russia.
The IRS has issued the last substantial package of regulations necessary to implement FATCA.
Chris Morgan reviews recent international tax developments, including updates from Canada, as well as the OECD’s BEPS project and common reporting standard, CJEU judgments on German exit taxes and the Hungarian ‘crisis tax’, and the M&S Supreme Court decision