Tax and the City briefing for May 2015

Mark Middleditch

Mark Middleditch (Allen & Overy) reviews recent tax developments affecting the City, including new consolidating regulations for country by country reporting; withholding tax exemptions for private placements; mandatory disclosure and CFCs; and banks’ compensation expenditure

Recent tax highlights affecting the City are as follows.

Country by country reporting

The International Tax Compliance Regulations SI 2015/878 came into force on 15 April.

These consolidating regulations bring together in one place the power for HMRC to collect information from financial institutions under the OECD common reporting standard (including as implemented in the EU under the Revised European Union Directive on Administrative Cooperation) and under the FATCA Intergovernmental Agreement with the USA. The International Tax Compliance (United States of America) Regulations SI 2014/1506 which previously dealt with FATCA reporting are now repealed.

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