The Dutch ministry of finance has issued a statement confirming that the Netherlands will be appealing the European Commission’s ruling in October that the country provided state aid to Starbucks Manufacturing EMEA BV.
HMRC has revised its interpretation of the residence articles in 16 double taxation agreements, taking the view that a tie-breaker clause should be used to decide a company’s residence. Previously, HMRC regarded dual-resident companies as outside the scope of the treaties.
The US Internal Revenue Service (IRS) upgraded the FATCA online registration system in November 2015 to enable sponsoring entities to add their sponsored entities and, if applicable, sponsored subsidiary branches.
Shiv Mahalingham (Duff & Phelps) provides a round-up of news affecting the transfer pricing sphere.
The EU and Liechtenstein have signed a new tax transparency agreement, which the EC has hailed as an ‘important step forward in the fight against tax evasion’.
EY reports that the US Treasury is reviewing whether the UK’s diverted profits tax (DPT), which came into force on 1 April 2015, is a creditable tax for US foreign tax credit purposes.
The Double Taxation Relief and International Tax Enforcement (Jersey) Order, SI 2015/Draft, brings into effect the arrangement set out in an exchange of letters between the UK and Jersey governments in September/October 2015, updating the territorial definitions.
Jill Gatehouse and Susanna Brain (Freshfields Bruckhaus Deringer) provide an expert practitioner review of the OECD’s initiative to tackle base erosion and profit shifting.
Tom Scott (McDermott Will & Emery) looks at hybrid arrangements and the effect of the OECD proposals.