The Organisation for Economic Co-operation and Development (OECD) base erosion and profit shifting (BEPS) project continues to dominate the international tax world. The UK government’s view has been published alongside the Budget and further significant discussion drafts published by the OECD itself. Draft legislation has been published to remove the extended time limit restriction introduced in Finance Act 2007 that impacted certain EU claims. Staying with EU law, the attorney general (AG) has issued an opinion on the Dutch fiscal unity rules. In Switzerland, guidelines on the taxation of principal companies have been published which could affect groups which already have or plan to establish principal company structures there.
This article represents the views of the author only, and does not necessarily represent the views or professional advice of KPMG in the UK.