BEPS

Daniel Head and Kashif Javed (KPMG) assess some of the practical challenges facing corporate groups.

 

Zoe Wyatt and Miles Dean (Milestone International Tax Partners) examine the EC’s proposals surrounding a fair and efficient tax system in the EU for the digital single market.

 

The definition of ‘related’ in the hybrid rules is extremely broad. Dan Neidle and Jemma Dick (Clifford Chance) explain how this could potentially cause companies to be denied interest deductions on ordinary commercial loans.

 

Jeremy Webster and Jamie Robson (Pinsent Masons) consider how the MLI amends existing DTTs, and examine whether the principal purpose test would apply in a given scenario.

 

Philip Greenfield (PwC) reports on the extent to which countries have started to adopt the BEPS recommendations. 

 

Hatice Ismail, Martin Shah and Gary Barnett (Simmons & Simmons) review the EC’s proposal for a directive to impose mandatory reporting obligations on intermediaries and taxpayers involved in certain cross-border tax planning arrangements.

 

The BEPS limitation on benefits article would hinder cross-border investment. Dan Neidle and Jemma Dick (Clifford Chance) consider why it’s likely to be of limited application.

 

Tim Sarson (KPMG) reviews the latest developments in the international tax world.

 

Mario Petriccione and Nick Gurteen (KPMG) consider the impact of DPT for multinationals operating in today’s global business environment and the need to comply with the increasing tax administrative burden.