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
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.
John Watson, former head of tax at Ashurst, with assistance of Martin Precious, reviews the options for reform of the international taxation of corporate profits, in view of the OECD's action plan on tackling base erosion and profit shifting.
Peter Clements and May Smith review the two proposed changes that the European Commission has recently made to the Parent-Subsidiary Directive, following its action plan on tackling base erosion and profit shifting, and what the implications are for the UK and other member states.
Chris Morgan reviews recent developments, including the recent CFC and dividend group litigation (Prudential Assurance Company Ltd), the AG’s opinion in Felixstowe and Emerging Market Series, and updates to tax rules in Brazil, Ireland and Norway.
HMRC has published RDR1: Guidance Note: Residence, Domicile and the Remittance Basis, which replaces the previous guidance in HMRC6 and applies from 6 April 2013. Readers are also referred to the separate guidance in RDR3: Statutory Residence Test.
The G20 leaders’ declaration published last week endorses the OECD proposal on BEPS and a new standard of information exchange. Sandy Bhogal provides a quick overview
Some immediate reaction on the OECD's Action Plan on Base Erosion and Profit Shifting.
James Bullock looks at the activist group's failed attempt to challenge HMRC
Business has supported establishment by the OECD of ‘uniform international rules on controlled foreign companies and on interest deductibility’
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