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HMRC has issued Revenue & Customs Brief 35/2014: Lok'nStore Group plc decision on calculating deductible VAT, which states that HMRC is not appealing the Upper Tribunal decision in favour of Lok’nStore Group plc’s partial exemption special method for apportioning residual input VAT o

The Scottish government has announced rates for the new land and buildings transaction tax (LBTT), which is to replace stamp duty land tax (SDLT), in its draft Scottish Budget for 2015/16. The nil rate applies up to £135,000, rising to 12% on transactions over £1,000,000.

The Taxation of Pensions Bill was introduced in the House of Commons on 14 October 2014.

Draft Finance Bill 2015 clauses

The government will publish draft clauses to be included in Finance Bill 2015 on Wednesday 10 December 2014, in the week following the Autumn Statement. Consultation on this draft legislation will run until 4 February 2015.

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.

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