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:
The number of tax avoidance schemes disclosed to HMRC has fallen by more than a third in the past year. According to law firm Pinsent Masons, the number of schemes disclosed is at its lowest point since disclosure of tax avoidance schemes (DOTAS) launched in 2004.
Jonathan Fletcher Rogers considers whether Aberdeen Asset Management signals the end of tax avoidance on employee benefits.
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:
The Sixth Meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes is being held on 21–22 November 2013 in Jakarta, Indonesia.
The Select Committee on Statutory Instruments (SCSI) has concluded that the International Tax Compliance (United States of America) Regulations, SI 2013/1962, may be ultra vires. These regulations bring into effect the intergovernmental agreement made on 12 September 2013.
Helen Lethaby reviews recent developments affecting the City, including profit deferral under AIFMD, compensating adjustments, new DOTAS rules and the Ingenious Media case.
The Supreme Court has found in favour of HMRC in the Cotter case, overturning the previous decision of the Court of Appeal.
The Cayman Islands has become the first overseas territory to sign a FATCA-style intergovernmental agreement with the UK for automatic exchange of information for tax purposes. Agreements have already been signed with the UK’s Crown dependencies: Jersey, Guernsey and the Isle of Man.