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.
Charles Yorke (Allen & Overy) reviews Action 4 of the BEPS report.
Alison Lobb (Deloitte) considers the permanent establishment threshold and the consequences for cross-border trading.
Tom McFarlane (Alvarez and Marsal Taxand UK) presents an overview of Action 13.
Jason Collins (Pinsent Masons) reports on the recommendations in relation to international dispute resolution.