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International update for July

International update for July

Tim Sarson’s latest summary of international developments.

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Partner and Brexit Tax & Location Lead

KPMG in the UK

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Brexit has been dominating the headlines, with the publication of the UK Government’s white paper on future relations with the EU and two Brexit-related bills passing through the House of Commons. The OECD has published discussion drafts on transfer pricing matters. Further countries have signed or ratified the BEPS multilateral instrument. In the EU, there have been two tax cases decided by the CJEU, and two member states have taken steps to implement ATAD. In local country news, Italy has provided guidance on R&D tax credits, while India provided guidance on the ‘place of effective management’ rules for foreign companies. On digital tax, the EU has promised ‘a modern and balanced regulatory framework’ for the digital economy; and the US Supreme Court has ruled that physical presence is no longer a prevailing standard that can be relied on by taxpayers for US state sales and use tax purposes.

In the latest of his regular articles for Tax Journal*, Tim Sarson rounds up recent international developments. This month’s article looks at:

  • Brexit developments in the UK;
  • OECD discussion draft on transfer pricing of financial transactions and reports covering guidance on hard-to-value intangibles (HTVI) and the transactional profit split method (PSM);
  • Updates on the Multilateral Instrument (MLI);
  • The EU’s mandatory disclosure regime for cross-border arrangements;
  • Court of Justice of the European Union (CJEU) tax cases on the use of corporation tax losses;
  • Local activity to implement the EU’s Anti-Tax Avoidance Directive (ATAD);
  • Italian research and development (R&D) guidance;
  • Indian guidance on ‘place of effective management’ (POEM) standards and implications for foreign companies; and
  • Updates on initiatives on the taxation of the digital economy worldwide.

* First published in Tax Journal on 27 July 2018. Reproduced with permission.

For further information please contact:

Tim Sarson

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