For any transaction involving bonds or notes, there are a number of potential difficulties that may arise, which may include issues involving stamp taxes, VAT, withholding tax, FATCA, and the tax treatment of the bond issuer and bondholders. Eloise Walker and Abigail McGregor provide a handy practice guide for advisers
Vicky Clarke answers a query on whether a UK insurance company needs to complete a W-8BEN-E form
Martin Zetter provides an update on transfer pricing developments from around the globe
Chris Sanger reviews the IMF’s recent report, Spillovers in international corporate taxation, which considers how national tax decisions have international impacts and offers some radical suggestions to the current international tax architecture
On 24 June 2014, the IRS published an update to the Foreign Financial Institutions (FFI) Agreement, under which financial institutions report information to the US authorities in place of a withholding tax.
Cathya Djanogly reviews the decision of the High Court in Privacy International on whether HMRC should have disclosed information about an investigation it was carrying out.
Chris Morgan provides an update of recent key developments, including: the EC state aid investigation into Apple, Starbucks and Fiat; CJEU judgments in two Dutch cases; and updates from Singapore, Sweden and Poland
David Harkness and Robert Sharpe consider the CJEU judgment in SCA Group Holding BV and its significance to the UK CFC rules
Peter Cussons examines issues of possible concern from an EU law perspective regarding the BEPS proposals made to date
The European Commission has opened state aid investigations into the transfer pricing arrangements of Apple, Starbucks and Fiat. Jonathan Schwarz takes a look at the important points