The UK Finance Bill contains legislation on the patent box, hybrids and royalty payments. In Europe, the EC published a proposal for public country by country reporting and the Advocate General of the CJEU published an opinion on Portuguese withholding tax rules. The Italian Supreme Court concluded that the Italian CFC regime is compliant with EU principles but a group of tax professionals in Italy have submitted a complaint to the EC arguing that it is not. Outside the EU, the Swiss Corporate Tax Reform III proposals continued their progress through parliament, and the Canadian Federal Budget included several announcements focused on implementation of the OECD’s BEPS recommendations.
In the latest of his regular articles for Tax Journal, Chris Morgan rounds up recent international developments. This month’s article looks at: