The UK has deposited its instrument of ratification for the ‘Multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting’ (MLI) with the OECD. The MLI will enter into force for the UK on 1 October.
Two orders give effect to a new double taxation convention (DTC) with Belarus and a Protocol amending the DTC with Ukraine, neither of which are yet in force.
Kazakhstan and Vanuatu have signed the CRS Multilateral competent authority agreement (CRS MCAA), bringing to 102 the number of signatories.
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