Andrew Boucher looks at what the controlled foreign companies reforms mean in practice
This month's international briefing by Chris Morgan focuses on US FATCA developments and a recent opinion of the Advocate General which challenges the conclusions of the court in Marks & Spencer.
KPMG welcomes progress on advance pricing agreements
There is a risk that revised controlled foreign companies rules will encourage transfer of profits into tax havens, says International Development Committee
Information is presented 'in a more logical way'
Alison Lobb and Clive Teitjen look at the recent trend for incorporating the arm's-length principle into areas of the UK corporate tax code beyond the transfer pricing rules
HM Treasury issued a joint statement announcing publication of the Model Intergovernmental Agreement to Improve Tax Compliance and to Implement FATCA.
Confidentiality of taxpayer information ‘has always been a fundamental cornerstone of tax systems,’ says OECD
The OECD has updated Article 26 of the OECD Model Tax Convention explicitly to allow tax authorities to request information on a group of taxpayers without naming them individually.
The CIOT has published a note of ‘initial points’ raised on behalf of its members in meetings with HMRC and HM Treasury to discuss the June 2012 response document.