International briefing for October 2014

One of the most surprising developments of the last month was the AG opinion concluding that the UK rules on cross-border group relief are legal. Also at the EU, finance ministers have agreed on an extended information exchange mechanism. The UK government has responded to the BEPS 2014 deliverables with a commitment to implement the OECD recommendations on hybrids. Overseas, there has been a significant Budget in Ireland, bringing to an end the ‘Double Irish’ structure; in Switzerland, major tax reforms are now in consultation phase; and the Supreme Court of India has rejected the taxpayer’s appeal in the Centrica case.