CROSS BORDER

Your monthly review of key international tax issues by Chris Morgan, with comment on the patent box and CFC proposals and the informal consultation on the debt cap, and details of recent cases on EU issues

Tax professionals have given a qualified welcome to detailed proposals for reform of the UK’s controlled foreign companies regime.

Cathryn Vanderspar and Charles Goddard examine how arguably outdated tax rules impact on the new financial landscape

Michael McKenna and Kunal Vyas review the impact of Bayfine UK and the OECD discussion draft on the meaning of ‘beneficial ownership’ on the interpretation of double tax treaties

The OECD has urged all countries to sign up to a revised international convention designed to help counter cross-border tax evasion.

A comprehensive double taxation convention between the UK and the Federal Democratic Republic of Ethiopia was signed on 9 June.

TIEAs signed in January 2010 between the UK and the following territories entered into force on 19 May:

The OECD Committee on Fiscal Affairs has invited public comments on draft changes to the commentary on the OECD Model Tax Convention concerning the meaning of the term ‘beneficial owner’. The term has given rise to different interpretations by...