United States: Tax Alert: Commissionnaires And Other PE Structures Under Scrutiny As Part Of BEPS

The OECD has recently published a discussion draft on the portion of its BEPS action plan dealing with permanent establishments and has titled this paper, “Preventing the Artificial Avoidance of PE Status 1 The title itself illustrates the OECD’s view on the matter: taxpayers have taken actions to “artificially” avoid PE status and thereby deprive source countries of deserved tax revenue.

Characteristic of the BEPS project as a whole, the OECD’s views on permanent establishments […]

By |December 12th, 2014|

UK: Complete Overhaul Of Stamp Duty Land Tax Announced By The Chancellor

In today’s Autumn Statement, George Osborne has announced sweeping changes to the way Stamp Duty Land Tax is calculated, promising that his reforms will deliver savings for 98pc of home buyers.

Under the old regime Stamp Duty Land Tax on residential property was paid at certain thresholds as follows:

In today’s Autumn Statement, George Osborne has announced sweeping changes to the way Stamp Duty Land Tax is calculated, promising that his reforms will deliver savings for […]

By |December 12th, 2014|

European Union: EC Investigates Transfer Pricing Arrangements On Corporate Taxation In Luxembourg And Ireland

Recently, the European Commission (EC) has published two main decisions taken last June to undergo investigations into transfer pricing arrangements on corporate taxation of Apple in Ireland and Fiat Finance and Trade in Luxembourg.

The European Commission’s crackdown on the deal between Irish tax authorities and Apple Inc. represents a leap forward in the growing global war on tax avoidance by multinational companies. Governments facilitating tax deals are now becoming a target.

The Commission utilised a […]

By |December 11th, 2014|