The OECD recently released its discussion draft on the reform of the permanent establishment (PE) rules. Richard Collier (PwC) examines the proposals
As part of the G20/OECD’s work on BEPS in relation to action 10 and transfer pricing of high risk transactions, the discussion draft on the transfer pricing of low value-adding intra-group services has been published. Alison Lobb (Deloitte) reviews the detail
Mark Middleditch (Allen & Overy) provides an update of recent developments, including: the announcement of new rules on hybrid mismatches; the high-risk promoters regulations; euro conversion clauses; FATCA; and the EC investigation into the Irish tax rulings over Apple
The financial transaction tax inches closer, write Richard Croker and Anna Burchner (CMS Cameron McKenna)
Jonathan Fletcher Rogers (Abbiss Cadres) answers a query on the taxation of share incentives for international employees
Germany and the UK have agreed a compromise proposal on patent box regimes. The agreement is based on the OECD's modified nexus approach requiring tax benefits to be connected directly to R&D expenditures, but seeks to address concerns with revised elements, including:
The International Consortium of Investigative Journalists (ICIJ) has published leaked documents setting out tax deals that some of the world’s largest multinational corporations struck with Luxembourg.
The EC published on Monday full details of its decision to rule in favour of the UK government’s aggregates levy credit scheme (ALCS), confirming that it was in line with state aid rules.
Peter Cussons (PwC) considers whether AG Kokott’s opinion, which urged the CJEU to reverse its decision in Marks & Spencer, will spell the end for cross-border loss relief
To anyone involved in the infrastructure sector, action point four of the OECD’s BEPS project – to ‘limit base erosion via interest deductions and other financial payments’ – is bad news for highly geared projects, writes Eloise Walker (Pinsent Masons)