The OECD has published a discussion draft on financial transactions, which deals with follow-up work in relation to BEPS Actions 8–10 (aligning transfer pricing outcomes with value creation). Comments on the draft are invited by 7 September 2018.
HMRC has entered an alliance with tax enforcement bodies in Australia, Canada, the Netherlands and the United States to share intelligence and expertise in the battle against international tax crime.
The European Commission has concluded, following an investigation begun in September 2016, that two tax rulings by the Luxembourg authorities in favour of companies in the Engie group (formerly GDF Suez) resulted in illegal state aid amounting to €120m.
The OECD has incorporated new guidance on hard-to-value intangibles (BEPS action 8) and the transactional profit split method (BEPS action 10) into its main transfer pricing guidelines. The OECD consulted on discussion drafts of the guidance in May/June 2017.
Interest on foreign loan
The European Commission has published the letter containing its detailed decision to approve the UK’s application to extend the enterprise management incentive (EMI) scheme. The Commission gave its approval on 15 May.
The government of the British Virgin Islands has announced a legal challenge to the provision in the Sanctions and Anti-Money Laundering Act 2018 obliging the UK government to impose publicly accessible registers of beneficial ownership on any British overseas territory failing to introduce such
The new Protocol to the UK/Uzbekistan double taxation convention, signed in January 2018, entered into force on 1 June 2018 (see https://bit.ly/2Jwhh3n).
In the UK, this is effective: