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• German draft tax law to avoid disadvantageous tax consequences resulting from Brexit

  Article

  Submitted: 18 October 2018

  The German Ministry of Finance has put forward draft provisions to ensure that Brexit does not have unintended adverse tax consequences for certain pre-Brexit cross-border reorganisations.

• OECD Discussion Draft on the transfer pricing aspects of financial transactions: Simmons & Simmons response

  Article

  Submitted: 07 September 2018

  Simmons & Simmons response to the discussion draft released by the OECD on 03 July 2018 containing guidance on the transfer pricing of financial transactions.

• Increased focus of tax authorities on transfer pricing valuation

  Article

  Submitted: 08 August 2018

  ​Clive Jie-A-Joen, Liu Lu and Fan Bai examine recent TP developments that are relevant for the arm's-length pricing of transactions of intangibles and other items of value between group entities resulting from business restructuring. Each of these developments is specific and can be useful considering the specific facts and circumstances of the case at hand.

• Advances to company with no immediate prospect of repayment still loan relationships

  Article

  Submitted: 02 August 2018

  Advances made to a company with no immediate prospect of repaying either the monies or interest on those monies were still loan relationships where they were properly contractually documented as loans.

• Overpaid tax on portfolio dividends: remedies and interest

  Article

  Submitted: 26 July 2018

  The Supreme Court has held that EU law required the UK to give credit against UK tax on foreign portfolio dividends based on the nominal rate of tax in the jurisdiction of the distributing company, but that neither EU nor UK law requires the payment of compound interest on repayments.

• Un redressement en matière de prix de transfert peut-il avoir une incidence sur la CVAE ?

  Article

  Submitted: 26 July 2018

  ​Un redressement en matière de prix de transfert peut avoir une incidence automatique sur la CVAE, selon le Conseil d’Etat.

• VAT and holding companies: involvement in the management of a subsidiary

  Article

  Submitted: 25 July 2018

  A holding company making taxable supplies of property to a subsidiary was involved in the management of that subsidiary and was able to obtain input VAT recovery in relation to costs incurred in acquiring its shareholding in that subsidiary.

• Loss streaming necessary on succession to trade

  Article

  Last Reviewed: 29 June 2018 / Submitted: 29 July 2016

  A taxpayer that acquired a loss making company and succeeded to its trade was only entitled to set the carried-forward trading losses from the acquired trade against the trading profits from that same trade.

• Danish withholding tax on dividends to foreign funds contrary to EU law

  Article

  Submitted: 28 June 2018

  Withholding tax on dividends paid to a foreign fund was contrary to the free movement of capital, in circumstances where domestic distributing funds were exempted from withholding.

• Commercial and practical approach required to determining source of interest

  Article

  Submitted: 25 June 2018

  The Court of Appeal has stressed the need for a commercial and practical approach to the multifactorial test of determining the source of interest when applying the UK withholding tax provisions.

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