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  • Abuse and economic reality: Newey remitted

    Artikel

    Veröffentlicht: 19 April 2018

    The Court of Appeal has remitted the long-running Newey case back to the FTT for reconsideration of the question whether the arrangements entered into were abusive.

  • Tax Journal VAT Briefing for April 2018

    Artikel

    Veröffentlicht: 16 April 2018

    Simmons & Simmons monthly contribution to Tax Journal analysing recent VAT developments.

  • The Amazon case: towards transfer pricing harmonisation?

    Artikel

    Veröffentlicht: 16 April 2018

    Pierre-Regis Dukmedjian and Alejandro Dominguez’s article on the European Commission’s State Aid decision in the Amazon case published in the 06 April 2018 edition of Tax Journal.

  • VAT recovery and non-taxable investment activities

    Artikel

    Veröffentlicht: 12 April 2018

    The Court of Appeal has referred to the ECJ questions concerning the ability of a business to recover input VAT on management services incurred in relation to non-taxable investment activities used to part finance the wider economic activities of that business.

  • Tax Avoidance Including Fragmentation

    Artikel

    Veröffentlicht: 11 April 2018

    HMRC is consulting until 08 June 2018 on measures to prevent the transfer of trading profits to unrelated foreign entities, including a targeted anti-avoidance provision and a new duty to notify HMRC of such arrangements and pay tax earlier.

  • Management fee rebates to fund investors not annual payments

    Artikel

    Veröffentlicht: 29 March 2018

    Rebates of fund management charges paid by an investment platform to investors were not “annual payments” for tax purposes and so were not subject to withholding tax.

  • Treasury Committee and Sub-committee inquiries into aspects of the tax system

    Artikel

    Veröffentlicht: 29 March 2018

    The Treasury Committee and Sub-Committees have commenced three separate inquiries into the VAT system, tax avoidance and evasion and HM Revenue and Custom's (HMRC) conduct of tax disputes.

  • Cayman Islands AEOI update: March 2018

    Artikel

    Veröffentlicht: 29 March 2018

    The Cayman Islands Department for International Tax Cooperation has re-opened its FATCA and CRS reporting portal and announced changes to its certification and notification forms, including introducing a lower threshold of 10% for the “Controlling Person” definition.

  • EU Commission's proposals for fair taxation of the digital economy

    Artikel

    Veröffentlicht: 26 March 2018

    The EU Commission has proposed two directives to reform the taxation of digital businesses operating in the EU, including an interim 3% tax on certain digital revenues and a long term proposal to recognise a “significant digital presence” for tax purposes based on a local user base.

  • Enhanced risk assessment for large business compliance

    Artikel

    Veröffentlicht: 26 March 2018

    HMRC will pilot a new system of categorising large businesses from a risk assessment perspective following feedback on their 2017 consultation.

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