UK charities are increasingly encouraged to become limited partners in private equity funds targeting US acquisitions. Thomas Dick (DLA Piper UK) examines the related tax issues.
Shiv Mahalingham (Duff & Phelps) provides a round-up of news affecting the transfer pricing sphere.
Mark Middleditch (Allen & Overy) reviews recent tax developments affecting the City, including UK FATCA rules in relation to holding and treasury companies; a FTT case on the assumption of debt on share sales; BEPS and the US proposals to combat treaty abuse; and the EU Commission’s action plan in relation to the new tax transparency package.
Allan Cinnamon reviews the latest tax treaty developments this month, including BEPS Action 6; amendments to the US Model Tax Treaty; diverted profits in Australia; PE profit allocations; a Swiss Supreme court decision on beneficial ownership of dividends; and treaty provisions relating to PEs, equipment leasing and hybrids.