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Property owned via onshore and offshore corporate structures – a ticking time bomb?
Recent legislative developments in Spain represent a risk to both clients and practitioners unaware of the changes to the tax rules. Fernando Leon Del Canto explains why.
Tax advisers in the UK are having to turn their attention to a relatively new..
Online Published Date:
06 May 2019
Appeared in issue:
Vol 24 No 04 - 06 May 2019
The roadmap to tackling digitalisation tax challenges
Grace Perez-Navarro provides an update on the OECD’s efforts to modernise the international tax system.
Strengthening the international tax system – to both eliminate tax barriers to cross-border trade and investment and to tackle tax..
Online Published Date:
06 May 2019
Appeared in issue:
Vol 24 No 04 - 06 May 2019
A new French tax on digital services
Following the adoption of the so-called “GAFA Tax” on digital services, Siamak Mostafavi and Fabrice Korenbeusser consider whether it is a temporary fix to the taxation of the digital economy.
Further to the failure by the G20 and the..
Online Published Date:
06 May 2019
Appeared in issue:
Vol 24 No 04 - 06 May 2019
CFC State Aid: UK’s appeal and EC decision published in Official Journal
The UK has raised four pleas in an action before the CJEU for the EC decision to be annulled and the EC decision has been formally published.
The UK’s appeal against the European Commission (EC) claim that the UK Controlled Foreign Company..
Online Published Date:
06 May 2019
Appeared in issue:
Vol 24 No 04 - 06 May 2019
Managing the transition from US GAAP and IAS 39 to CECL and IFRS 9
David Binder provides some practical points to consider while preparing for the new accounting standards.One of the most frequently underestimated impacts of transitioning to the new financial accounting standards – Current Expected Credit Loss..
Online Published Date:
28 May 2019
Appeared in issue:
Vol 24 No 02 - 28 May 2019
Full European Commission state aid decision on UK CFC rules
European Commission concludes on whether UK CFC finance company exemption constitutes state aid.The European Commission (EC) has published its full decision as to whether the UK controlled foreign company (CFC) finance company regime under Part 9A..
Online Published Date:
28 May 2019
Appeared in issue:
Vol 24 No 02 - 28 May 2019
Selective advantage
Following an in-depth investigation that has been ongoing since October 2017, the European Commission has found that while the UK’s controlled foreign company (CFC) finance company regime did not constitute state aid in that it supports the proper..
Online Published Date:
28 May 2019
Appeared in issue:
Vol 24 No 02 - 28 May 2019
Revenue defeat in first substantial transfer pricing case to reach the Danish Supreme Court
In the first transfer pricing case ever to reach the Danish Supreme Court, the Ministry of Taxation’s claims were based on substantive as well as procedural allegations, raising legal questions of principle and of general importance for Danish..
Online Published Date:
28 May 2019
Appeared in issue:
Vol 24 No 02 - 28 May 2019