The Double Taxation Relief and International Tax Enforcement (Turkmenistan) Order, SI 2016/1217, will bring into effect the UK/Turkmenistan Double Taxation Convention, signed on 10 June 2016. The convention has not yet entered into force.
49 countries, besides the UK, Germany, France, Italy and Spain, are now participating in the initiative for automatic exchange of beneficial ownership information, first announced in April 2016. The latest to join was Mauritius.
On 6 December, the council of EU finance ministers set out their conclusions on the European Commission’s latest corporate tax reform package, issued on 25 October, which included: a two-step approach to establishing a common consolidated corporate tax base (CCCTB); an improved double taxation di
HMRC has published draft guidance on the application of the hybrid mismatch legislation in Finance Act 2016 Sch 10, which takes effect from 1 January 2017. When finalised, this guidance will be incorporated into HMRC’s international manual.
The new UK/Uruguay double taxation convention, signed in February 2016, entered into force on 14 November 2016. The convention has effect:
On 6 December, the Council of the EU adopted a directive granting tax authorities access to information held by authorities responsible for the prevention of money laundering, including the requirement for member states to provide access to information on the beneficial ownership of companies.The
The Jersey government has published the findings of a review its high-value resident (HVR) regime, which was introduced in its current form in July 2011. The review recommends improvements, including:
Christina HJI Panayi (Queen Mary University of London) identifies the main EU tax developments in 2016, including the anti-tax avoidance package, decisions in state aid cases, the reform of corporate tax and the relaunch of the common consolidated corporate tax base.
Simon Whitehead and Joseph Irwin (Joseph Hage Aaronson) review the Court of Appeal’s recent judgment in the franked investment income group litigation.
The OECD has published the agreed text for the ‘multilateral convention to implement tax treaty related measures to prevent BEPS’, following the conclusion of negotiations involving more than 100 countries.