Allan Cinnamon reviews the latest tax treaty developments, including UK companies seeking group relief for losses of foreign subsidiaries; potential exposure to Indian tax on consultancy fees and exemptions in operating aircraft; and Maltese companies enjoying special tax treatment potentially being denied treaty benefits.
The UN Conference on Trade and Development's World Investment Report 2015 argues that corporate tax anti-avoidance discussions should focus more on investment policy in developing countries and proposes a set of guidelines for coherent international tax and investment policies.
The OECD has published the public comments received on its discussion draft on BEPS Action 6 (preventing treaty abuse). The revised discussion draft follows the original discussion draft which was published on 21 November 2014.
Latvia has written to the EC to remove Bermuda as one of its ‘blacklisted’ countries. This follows reports of Poland doing the same last week, which means the number of countries targeting Bermuda is now down from eleven to nine.
Mauritius has signed the OECD convention providing for the comprehensive multilateral exchange of information and assistance in tax collection matters.
Does the Supreme Court judgment in Pendragon represent a shift of emphasis? Can offshore schemes of the Newey-type scheme survive? Michael Conlon QC and Rebecca Murray (Temple Tax Chambers) examine the impact of recent case decisions on VAT planning arrangements.
Chris Morgan (KPMG) provides an update of recent developments, including an update on BEPS Actions 6 and 13, a new action plan on CCCTB and the recent cases of X AB and Groupe Steria.
A scheme to enhance DTR failed