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.
On 16 January 2015, the European Commission published the non-confidential details of its decision taken in October 2014 to open a formal state aid investigation into a ruling by the Luxembourg tax authorities in favour of Amazon’s transfer pricing arrangements dating back to 2003.
The OECD has released public comments on the BEPS discussion draft on action 14 (making dispute resolution mechanisms more effective). See the 413-page document.
Peter Cussons examines the potential EU law and international issues facing the UK's diverted profits tax.