By Andrew Goldstone & Jonathan Legg, Mishcon de Reya
Sjoerd Douma & Bob van der Made, PwC, set out the key proposals.
Loopholes in the Parent-Subsidiary Directive (Council Directive 2011/96/EU) exploited by companies avoiding corporation tax are to be closed as part of a European Commission’s action plan to tackle tax evasion. The proposed reforms to the directive include:
As part of the BEPS action plan, the OECD is asking for comments by 22 December 2013 on an approach to addressing the tax challenges of the digital economy, as well as gathering information on specific business models employed in the sector.
Gibraltar and Bermuda have become the second and third British overseas territories (after the Cayman Islands) to sign a FATCA-style intergovernmental agreement (IGA) with the UK for automatic exchange of information for tax purposes.
Martin Zetter provides this month’s review of developments, focusing on those at OECD level and in France and Russia.
Following the OECD meeting in Paris last week, Bill Dodwell and Alison Lobb examine the challenges in implementing country by country reporting and its proposed common template.
Richard Woolich reviews changes to the place of supply rules in 2015 and the extended one stop shop.
Malcolm Finney answers a query on split-year residence and the sale of shares.
The OECD has launched a consultation on a series of minor changes to the OECD Model Tax Convention. The majority are minor editorial or clarificatory changes, but they do include additional commentary on: