The BBC revealed (29 May) that Anderson Group, one of the most high-profile companies providing services to the recruitment industry, is promoting what it calls an ‘aggressive’ tax avoidance scheme that exploits the employment allowance introduced by the government in 2014.
Mark Middleditch (Allen & Overy) reviews recent tax developments affecting the City, including UK FATCA rules in relation to holding and treasury companies; a FTT case on the assumption of debt on share sales; BEPS and the US proposals to combat treaty abuse; and the EU Commission’s action plan in relation to the new tax transparency package.
The OECD’s BEPS project might be still underway, but the impact of its work and changing attitudes towards tax transparency is already being felt among UK corporates, according to separate surveys by PwC, Deloitte and EY.
The OECD invites comments by 18 June 2015 on a new discussion draft for action 8 of the BEPS action plan on the transfer pricing of hard-to-value intangibles.
The OECD has published its package of model legislation and competent authority agreements to help tax administrations implement the proposed requirement for multinational companies to report transfer pricing information on a country by country basis, starting in 2016.
Australia, Canada, Chile, Costa Rica, India, Indonesia and New Zealand are the latest countries to sign the Multilateral Competent Authority Agreement (MCAA) on automatic exchange of information under the OECD/G20 standard.
The UK and Kosovo signed a double taxation convention on 4 June 2015, which will replace the 1981 convention between the UK and the Socialist Federal Republic of Yugoslavia with respect to Kosovan taxes and will cover avoidance of double taxation and prevention of fiscal evasion with respect to t
HMRC has substantially revised its guidance on follower notices and accelerated payments, published in draft in July 2014, to support the ongoing drive for new anti-avoidance legislation.
The European Commission has agreed to relaunch work on establishing a common consolidated corporate tax base (CCCTB) for EU member states, as part of the tax transparency action plan to be launched later this month.