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INTERNATIONAL TAXES


The OECD has released two discussion drafts for public consultation, with comments invited until January.

Richard Woolich (DLA Piper) points out ten practical points to understand in relation to the new regime for all businesses when managing their cross-border supplies, both B2B and B2C

Chris Morgan (KPMG) provides an update on recent international developments, including: the CJEU’s release of the AG opinion on the UK rules on cross-border group relief following Marks & Spencer; EU finance ministers’ agreement on an extended information exchange mechanism; Ireland’s 2015 Budget announcement on the ‘double Irish’ tax structure; corporation tax reform III in Switzerland; and the Centrica case in India.

Advocate General Kokott’s opinion has been published on the European Commission’s action against the UK for failing to properly implement the decision in the Marks & Spencer cross-border group relief case.

The ‘VAT gap’ across the EU in 2012 stood at an estimated €177bn (£139.8bn), or 16% of the total expected VAT revenues of 26 member states, according to a European Commission study.

With recent events suggesting an increased interest from the EC in fiscal state aid, taxpayers would benefit from an early awareness of state aid risks, and advisers should also be careful to advise fully on these. Kelly Stricklin-Coutinho (Thirty Nine Essex Street) reports

Timothy Lyons QC (Thirty Nine Essex Street) looks at state aid and the European Commission’s investigations into Ireland’s tax ruling over Apple, and Luxembourg’s tax ruling over Fiat.

The European Commission has opened an ‘in-depth investigation’ over what it considers to be an ‘unorthodox’ tax deal by Luxembourg with online retailer Amazon.

The government has confirmed it will publish a consultation document at the Autumn Statement later this year on new measures to prevent multinational companies exploiting differences between countries’ tax rules through the use of ‘hybrid mismatch’ arrangements.

Residence and absence from the UK

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