Steve Bousher (Joseph Hage Aaronson) reviews recent decisions on accelerated payment notices as a new counter avoidance power used by HMRC.
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.
HMRC is taking a light touch to penalties for late self-assessment tax returns, writes Paul Aplin.
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 Times reported (10 June) that the chancellor is poised to axe £3.5bn bank ‘as he tries to head off a decision by Britain’s largest lender to move its headquarters overseas.’ The newspaper reported that the announcement is due to be made at the annual Mansion House speech on Wednesday
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.
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.