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DOUBLE TAX RELIEF


Heather Self considers the changes made to the Model Tax Convention (MTC) and what these updates mean in practice.

Scottish independence would raise a host of new challenges for the UK tax system. Dominic Robertson considers the likely impact.

The monthly round-up by Chris Morgan, with news from the OECD’s BEPS project, two CJEU cases and the latest from France, India and Chile

Card image Alastair Munro, Ben Eaton, Alastair Munro

Mark Eaton and Alastair Munro suggest that the wording of the draft legislation is too wide and may limit claims to double tax relief in circumstances where that does not appear to be intended

Colin Garwood, head of group tax at InterContinental Hotels Group, provides an industry view on BEPS related issues and responds to a recent call for a top-up tax.

John Watson, former head of tax at Ashurst, with assistance of Martin Precious, reviews the options for reform of the international taxation of corporate profits, in view of the OECD's action plan on tackling base erosion and profit shifting.

The following draft Orders in Council have been laid before the House of Commons for approval:

Some immediate reaction on the OECD's Action Plan on Base Erosion and Profit Shifting.

HMRC has announced that the (DTTP) scheme has been revised from April 2013. The scheme operates for overseas corporate lenders in a country with which the UK has a double taxation treaty that includes an interest or income from a debt-claims...
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