Corporate

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  • Cayman Islands AEOI update: March 2018

    Article

    Submitted: 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.

  • Enhanced risk assessment for large business compliance

    Article

    Submitted: 26 March 2018

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

  • OECD Model Mandatory Disclosure Rules for CRS avoidance arrangements

    Article

    Submitted: 22 March 2018

    The OECD has issued model rules to require disclosure by promotors and service providers of schemes to avoid the need for disclosures under the CRS.

  • OECD Interim Report on the tax challenges arising from digitalisation

    Article

    Submitted: 20 March 2018

    The OECD’s Interim Report on the tax challenges of the digital economy highlights the broad disagreement amongst its members as to whether there is a need for fundamental changes to the international tax rules allocating taxing rights in relation to digitalised business models.

  • Entrepreneurs' Relief: gains before dilution

    Article

    Submitted: 14 March 2018

    The Government proposes to allow individuals, whose shareholding in a trading company is diluted below 5% by an issue of shares to raise funds, to elect to claim Entrepreneurs’ Relief by reference to a deemed disposal of the shares at that time.

  • HM Treasury's updated position paper on taxation of the digital economy Restricted access

    Article

    Submitted: 14 March 2018

    The UK Government has published an update on its position paper in relation to its proposals to tax online businesses deriving value from user-created value in the UK.

  • Freedom of establishment and fiscal unity

    Article

    Last Reviewed: 08 March 2018 / Submitted: 26 October 2017

    The ECJ has held that Dutch rules restricting deductions for interest on a related party borrowing for investment in a foreign subsidiary are contrary to EU law.

  • Luxembourg publishes list of jurisdictions for CbC reporting purposes

    Article

    Submitted: 02 March 2018

    On 20 February 2018, the Luxembourg government published a regulation listing which countries are to be considered Reportable Jurisdictions under the Luxembourg rules on country by country (CbC) reporting.

  • Revenue based UK tax on tech companies a step nearer?

    Article

    Submitted: 23 February 2018

    The Government has indicated that a tax on revenues is potentially its preferred option for ensuring that digital companies pay a fair amount of tax on activities which leverage large user groups in the UK.

  • Changes to UK securitisation companies tax regulations

    Article

    Submitted: 22 February 2018

    Long-awaited tax changes to the UK securitisation companies regime will make a number of helpful changes to the regime, including ensuring that such companies are not subject to annual payments withholding tax on residual payments.

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