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INTERNATIONAL TAXES


HMRC has announced that a first-time comprehensive double taxation convention between the UK and Algeria was signed in Algiers on 18 February 2015 by Philip Hammond MP, secretary of state for foreign and Commonwealth affairs, and Ramtane Lamamra, minister of foreign affairs of Algeria.

Christopher Morgan (KPMG) provides an update of recent developments, including: the OECD’s BEPS project; the CJEU decision in the EC’s challenge to UK cross-border relief; the Prudential Assurance case; the EC investigation into Belgium’s excess profit rulings; and news from Ireland and the US.

Andrew Goldstone and Charlie Sosna (Mishcon de Reya) round up the latest private client news, including: the remittance basis charge consultation; a report on tax incentives for art; Hutchings; and BiGDUG Limited Remuneration Trust (from Guernsey)

Martin Zetter (Macfarlanes) summarises recent developments, including the latest from the OECD’s BEPS project, as well as updates from the UK, Spain, the US and Singapore

President Obama has proposed a levy for US corporations on profits located abroad, which are not repatriated to the US. Kristin Konschnik and Mitchell R. Kops (Withers) consider the proposals and what effect they may have in practice

The European Parliament voted on 12 February to set up a special parliamentary committee to look into EU member states’ ‘tax rulings and other measures similar in nature or effect’ and make recommendations for the future.

Nick Skerrett and Gary Barnett (Simmons & Simmons) examine the issues around EC state aid investigations following the announcement of the investigation into Belgium

The CJEU judgment in European Commission v UK has rejected a challenge to the UK group relief legislation, following on from the Marks and Spencer litigation. Rupert Shiers (Hogan Lovells) reviews the decision and asks where this leaves us.

The OECD and G20 have agreed three key elements towards the implementation of BEPS measures on tax avoidance by multinationals:

Allan Cinnamon provides an update on tax treaty developments

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