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INTERNATIONAL TAXES


The OECD has released a group of documents that will form the basis of the mutual agreement procedure (MAP) peer review and monitoring process under Action 14 of the BEPS action plan. The MAP is the framework for resolving tax-treaty related disputes.

The documents include:

Brazil, Guernsey, Jersey, the Isle of Man and Latvia have signed the multilateral competent authority agreement (MCAA) for automatic exchange of country by country reports, bringing to 49 the total number of signatories.

Andorra has become the 86th member of the OECD’s ‘inclusive framework’ on BEPS implementation. The inclusive framework provides a forum for a broad range of countries, representing varying levels of development, to participate on an equal footing in the OECD’s committee on fiscal affairs.

Allan Cinnamon (Cintax the Word Ltd) provides a quarterly update on recent tax treaty developments.
 

The European Commission has now made available the public version of its decision issued in October 2014 to extend its formal state aid investigation into the tax rulings procedure contained within the Gibraltar corporate income tax regime (ITA 2010) in force since 2011.

The European Parliament’s inquiry committee investigating the ‘Panama papers’ is also looking into the recent ‘Bahamas leaks’, a cache of documents leaked in September to journalists working with the international consortium of investigative journalists, naming politicians and others linked to co

With the UK’s continuing attractiveness as a holding company tax jurisdiction, Jonathan Cooklin and Dominic Foulkes (Davis Polk) consider the scope of technical UK tax issues that have a direct bearing on the drafting of merger agreements and related documents which implement these transactions.
 

HM Treasury has added Brazil to the list of countries that have declared their support for the initiative to establish automatic exchange of information on beneficial ownership. This brings to 48 the number of countries now participating.

Tim Sarson (KPMG) takes over Chris Morgan’s long-running update on international issues. This month, Tim examines developments on BEPS, state aid and transfer pricing, among others.

 

The European Commission has opened an in-depth investigation into Luxembourg’s tax treatment of the GDF Suez group (now Engie).

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