Two of the BEPS deliverables that the OECD issued on 16 September indicate transfer pricing changes. These relate to intangibles and documentation. Martin Zetter (Macfarlanes) takes a look.
Mark Middleditch (Allen & Overy) provides this month’s update, including: the UT decision in The Vaccine Research Limited Partnership; the G20 meeting of finance ministers and BEPS; the targeting of the quoted Eurobond exemption loophole; and the latest HMRC guidance on additional Tier 1 capital for foreign banks
Timothy Lyons QC (Thirty Nine Essex Street) looks at state aid and the European Commission’s investigations into Ireland’s tax ruling over Apple, and Luxembourg’s tax ruling over Fiat.
The European Commission has opened an ‘in-depth investigation’ over what it considers to be an ‘unorthodox’ tax deal by Luxembourg with online retailer Amazon.
With this autumn seeing the last political party conferences before the 2015 general election, the three main parties have made promises on tax and spending.
Conservatives:
In a speech to the Securities Industry Conference on 3 October, financial secretary to the Treasury David Gauke MP rejected criticism in international circles that the UK’s patent box facilitates profit shifting.
The Revenue Scotland and Tax Powers Bill received royal assent on 24 September 2014. This Act is the third of three related Acts; the first two Acts introduced land and buildings transaction tax (LBTT) and Scottish landfill tax.
Chris Lallemand (Smith & Williamson) discusses some contrasts between the UK implementing legislation for the UK/US IGA, equivalent US regulations and HMRC’s guidance
The budget deficit should be falling fast as growth accelerates, but it is not – and government tax policy may be to blame, reports David Smith
Bill Dodwell and John Macintosh (Deloitte) examine the further devolution of tax powers to Scotland.