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INTERNATIONAL TAXES


On 20 September, the Council of the EU approved the conclusion of an agreement with Andorra giving their tax administrations improved cross-border access to information on the financial accounts of each other’s residents.

The Guernsey government is consulting until 21 October 2016 on the legislation required in order for the States of Guernsey to introduce country by country reporting. See www.gov.gg/cbCR

HM Treasury has added Norway 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 47 the number of countries now participating.

News report


  • US tech giant Apple was granted illegal state aid by Ireland, the EC ruled on Tuesday, and must now pay up to €13bn (£11bn) in back taxes, plus interest. 

Chris Morgan (KPMG) assesses the latest developments that matter in the international tax arena.

Ashley Greenbank (Macfarlanes) considers the proposals for the introduction of further adjustments to counteract the financial benefits of cash flows arising from non-arm’s length transfer pricing.

BEPS Action 14 sets out the principles for resolving international tax disputes in the future. The International Chamber of Commerce will be contributing to this debate at an OECD level. Ian Hyde (Pinsent Masons) and Robert Thomas (chair of the UK tax committee of the International Chamber of Commerce) share the findings of a recent ICC UK survey, which reveals strong support for introducing a mandatory binding arbitration and for greater taxpayer involvement in the arbitration process.
 

On 12 July, the EU and Monaco signed a new tax transparency agreement, under which they will automatically exchange information on the financial accounts of each other’s residents from 2018.

Discussion draft on group ratio rule under BEPS Action 4: The OECD invites comments by 16 August 2016 on a discussion draft which deals with elements of the design and operation of the group ratio rule under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.

The EU Parliament has voted to endorse the report of the ‘TAXE 2’ special committee on tax rulings, calling for sanctions against non-cooperative tax jurisdictions, action against abuse of ‘patent box’ regimes, a code of conduct for banks and tax advisers, tax good governance rules in EU trade ag

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