Scottish independence would raise a host of new challenges for the UK tax system. Dominic Robertson considers the likely impact.
Chris Morgan reviews recent developments in the international tax sphere, including: the two changes to the CFC exemption contained in FB 2014; a summary of the CJEU’s rejection of the UK’s FTT challenge; proposed amendments to the EU’s Parent-Subsidiary Directive; and updates from India and Germany
Jackie Wheaton answers a query on whether interest has a UK source, reviewing the key issues following Perrin v HMRC
For borrowers and lenders subject to FATCA withholding, maintaining FATCA grandfathering on a debt instrument may be critical to avoiding FATCA withholding tax, writes Reed Carey
Vimal Tilakapala and Anne Powell examine the recent decision in UK v Council of the European Union, in which the CJEU decided that the UK’s legal claim in relation to the EU financial transaction tax was admissible, but premature.
Jonathan Levy comments on EU proposals to reduce cross-border red tape
The US Internal Revenue Service has announced a relaxation of enforcement and administration of the due diligence, reporting and withholding provisions under FATCA for calendar years 2014 and 2015 for entities which have made ‘good faith efforts to comply’ with the regulations.
A round up of other tax news:
The CJEU confirmed that an investment fund with a registered office in the US was entitled to claim an exemption from withholding tax on dividends granted by Poland only to domestic funds. This has implications for EU member states that grant exemptions only to domestic and European funds, writes Philip Baker QC
Stephen Camm reports on the ending of traditional Swiss banking secrecy