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INTERNATIONAL TAXES


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

The International Monetary Fund has called for a ‘comprehensive reform’ of the US tax system in the concluding statement of its annual ‘Article IV’ consultation issued in June (see http://bit.ly/29D2CPf).

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

Tom Wesel and Zoe Wyatt (Milestone International Tax Partners) review the revised EC’s Anti-Tax Avoidance Directive which will soon be adopted by the European Parliament to ensure a consistent and uniform implementation of BEPS recommendations across the EU.
 

The European Commission’s Anti-Tax Avoidance Directive shows that the Commission clearly doesn’t trust member states of the EU to implement the OECD’s BEPS 2015 recommendations, write Zoe Wyatt & Tom Wesel (Milestone International Tax Partners). 

The US Treasury recently issued new regulations to deter corporate ‘inversions’, where a US parented company and a non-US company combine and locate the tax residence of the merged company in a non-US jurisdiction. Joseph Goldman and Anthony Whall (Jones Day) review their impact.
 
Chris Morgan (KPMG) assesses the latest developments that matter in the international tax arena.
 

HM Treasury has added India 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 41 the number of countries now participating.

The European Parliament has voted to set up an inquiry committee into the ‘Panama papers’ revelations of detailed information on offshore companies and their ultimate beneficiaries.

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