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
Eloise Walker and Robbie Chen (Pinsent Masons) consider the ambit of the new GAAR in the People’s Republic of China
US President Barack Obama faced a backlash after proposing, in the $4trn budget for the 2016 financial year that was presented to Congress on 2 February, a minimum 19% tax on US multinationals’ foreign income and a one-off tax (at 14%) on previously untaxed foreign deferred profits.
The Indian government will not be appealing the Bombay High Court’s decision in Vodafone lndia Services Pvt. Ltd AY 2009-10 (WP No.871120).
CFC and dividend group litigation: outstanding issues
Chris Morgan (KPMG) provides a review of recent global developments, including: the diverted profits tax; updates from the OECD; the FII GLO High Court decision; ECOFIN, and tax news from Japan, Brazil, Norway and Luxembourg.
Martin Zetter (Macfarlanes) reports on the latest transfer pricing news, with updates on Finland, Czech Republic, South Korea and the latest BEPS discussion drafts
The government announced a new exemption for withholding tax on private placements – a potentially important source of non-bank funding for UK businesses – at the Autumn Statement. James Hume (Slaughter and May) reports.