Tax

Latest

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  • Treaty relief and non-CIV funds discussion draft

    Article

    Submitted: 16 January 2017

    The OECD is consulting on examples to illustrate the interaction between the BEPS Action 6 treaty provisions and the treaty entitlement of non-collective-investment vehicle funds.

  • Wheels keep turning

    Article

    Submitted: 10 January 2017

    Wheels Common Investment Fund Trustees has been allowed to amend its claim for repayment of overpaid VAT on investment fund management services to a defined benefit scheme to argue that the imposition of VAT was in breach of EU law since similar services provided by an insurer are treated as exempt insurance supplies.

  • HMRC guidance on bonus clawback arrangements

    Article

    Submitted: 10 January 2017

    Recently released HMRC guidance clarifies HMRC’s approach to the tax treatment of the clawback of bonuses and other payments made to employees.

  • Crime, fraud and investigations 2017: Criminalisation of compliance failures

    Article

    Last Reviewed: 13 January 2017 / Submitted: 05 January 2017

    ​A consultation is expected in early 2017 on a broad new form of corporate criminal liability, which will elevate the importance of compliance programmes.

  • Luxembourg passes country-by-country reporting law Restricted access

    Article

    Submitted: 05 January 2017

    The Luxembourg Government passes its law transposing the EU Council Directive on the mandatory automatic exchange of information in the field of taxation.

  • Luxembourg issues new transfer pricing circular for companies carrying out intra-group financing transactions

    Article

    Submitted: 04 January 2017

    This article summarises the key points arising from the Luxembourg tax administration's Transfer Pricing Circular, which sets new standards for the tax treatment of companies carrying out intra-group financing transactions.

  • OECD updates BEPS report on interest deductions

    Article

    Submitted: 23 December 2016

    The OECD has released further guidance on the group ratio rule and addressing BEPS involving interest deductions in relation to banking and insurance groups.

  • State Aid and selectivity in tax cases Restricted access

    Article

    Submitted: 23 December 2016

    In a decision that may play an important role in the forthcoming review of the Commission’s decisions on tax rulings, the ECJ has held that tax measures which are not aimed at any particular business or activity but derogate from the general scheme of taxation in a Member State in a discriminatory manner may amount to illegal State Aid.

  • The principle of equivalence and VAT appeals

    Article

    Submitted: 23 December 2016

    The Court of Appeal has held that UK VAT rules requiring payment of disputed VAT before a taxpayer may appeal on assessment do not breach EU rules.

  • The new VAT and indirect taxes avoidance disclosure regime

    Article

    Submitted: 21 December 2016

    The Government will introduce a new regime for disclosing VAT and other indirect tax avoidance schemes, placing the primary responsibility on the promoter of such schemes.

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