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  • A Luxembourg IP box tax regime in a BEPS fashioned way


    Submitted: 18 June 2018

    An article published in the June 2018 edition of “AGEFI Luxembourg” on Luxembourg’s replacement IP box.

  • ECJ confirms Marks & Spencer ruling on cross-border losses applies to permanent establishments


    Submitted: 15 June 2018

    The ECJ has applied the principles set out in its 2005 Marks & Spencer ruling to the final losses incurred by a permanent establishment of a Danish company located in Finland, notwithstanding the option of an international joint taxation regime in Denmark.

  • Large business tax strategies: too big to fail?


    Submitted: 13 June 2018

    This feature article by Nick Skerrett, Martin Shah and Rebekka Sandwell for PLC Magazine considers the requirement for large businesses to publish a tax strategy one year on from the requirement becoming effective.

  • Freedom of establishment and transfer pricing rules


    Submitted: 05 June 2018

    For transfer pricing rules to be compatible with the fundamental freedoms, a taxpayer must be given the opportunity to provide justifications for non-arm’s length terms, which may be based on the interests of the taxpayer as a shareholder in the foreign subsidiary concerned.

  • Dutch Transfer Pricing Decree interprets BEPS Changes


    Submitted: 31 May 2018

    A new Dutch transfer pricing decree sets out important aspects of the Dutch Tax Administration’s interpretation of the arm’s length principle.

  • Off-payroll working in the private sector


    Submitted: 21 May 2018

    The Government is consulting on options to tackle non-compliance with the IR35 rules in the private sector, including the possibility of making the engager responsible for ensuring that income tax and NICs are accounted for to HMRC when the rules apply.

  • HMRC updates list of CRS reportable jurisdictions


    Submitted: 17 May 2018

    HMRC has removed six jurisdictions from the list of reportable jurisdictions for the purposes of the Common Reporting Standard.

  • Cayman Islands AEOI update: March 2018


    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


    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


    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.

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