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
Chris Lallemand (Smith & Williamson) discusses some contrasts between the UK implementing legislation for the UK/US IGA, equivalent US regulations and HMRC’s guidance
Jo Summers (PWT Advice) answers a query on a client – who is non-domiciled, but has been UK tax resident for a number of years – and whether his children will have to pay the non-dom remittance charge
Richard Collier and Philip Greenfield (PwC) examine the OECD’s first set of recommendations for tackling base erosion and profit shifting (BEPS) - finding few surprises, but no let up.