A draft EU Council directive, known as ATAD 3, was issued by the European Commission as a proposal at the end of last year. The directive is aimed at countering the misuse of 'shell' entities and could impose adverse tax and...more
Following the agreement of the EU/UK Trade and Cooperation Agreement (the “Brexit Deal”), HMRC has unexpectedly announced a substantial restriction to the way in which DAC6 will be applied in the UK. Although the law has...more
On 24 June, the Council of the European Union formally adopted a directive giving EU Member States the option to defer by six months the timetable for reporting under DAC6.
...more
Political Agreement -
Following the recent European Commission proposal to postpone the initial reporting deadlines for “DAC6” by three months, EU Commission proposes extension of the DAC6 reporting deadlines, a political...more
On Friday 8 May 2020, the European Commission announced a proposal to postpone by three months the initial reporting deadlines for “DAC6”, the incoming mandatory disclosure regime for potentially aggressive tax arrangements....more
5/15/2020
/ Coronavirus/COVID-19 ,
Cross-Border Transactions ,
Deferred Action ,
EU ,
European Commission ,
Filing Deadlines ,
Financial Institutions ,
Mandatory Disclosure Rules ,
Member State ,
Reporting Requirements ,
Time Extensions ,
UK
Below please find a list of global tax measures in response to COVID-19.
United States -
On March 25 and March 27 the U.S. Senate and House of Representatives, respectively, passed the Coronavirus Aid, Relief and...more
As part of the series of announcements made in the 2020 Budget, HM Treasury released a consultation document relating to the tax treatment of UK asset holding companies in the context of alternative fund structures...
The...more
HMRC has released a consultation document in respect of its draft regulations implementing the EU mandatory tax disclosure rules that will apply from 1 July 2020 to intermediaries and relevant taxpayers in relation to...more
7/30/2019
/ Consultation Periods ,
Cross-Border Transactions ,
Disclosure Requirements ,
EU ,
Foreign Taxpayers ,
HMRC ,
Intermediaries ,
International Tax Issues ,
Legal Professional Privilege ,
Penalties ,
Tax Avoidance ,
Tax Evasion ,
Transfer Pricing ,
UK
The European Council has adopted new rules aimed at providing EU tax authorities with advance information in relation to aggressive cross-border tax planning. A failure to provide prompt disclosure of such arrangements could...more
The European Court of Justice (ECJ), in the case of Brisal, has determined on 13 July 2016 that national law which prohibits a non-resident taxpayer from deducting financing/operating costs from interest withholding tax...more
The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more
7/2/2016
/ CFCs ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Customs ,
Dividends ,
EU ,
European Economic Area (EEA) ,
Exit Tax ,
ICAV ,
Income Taxes ,
International Tax Issues ,
Referendums ,
Stamp Taxes ,
Tax Treaty ,
Transfer Pricing ,
UK ,
UK Brexit ,
Value-Added Tax (VAT)
The Court of Justice of the European Union (CJEU) recently issued a decision rejecting the UK government’s initial legal challenge against the proposed introduction of a financial transactions tax (FTT) in Europe. The...more
The European Commission on 14 February 2013 adopted a proposal for a Directive1 authorising eleven countries – Belgium, Germany, Estonia, Greece, Spain, France, Italy, Austria, Portugal, Slovenia and Slovakia (the “FTT Zone”)...more
Two recent decisions of the European Court of Justice (“ECJ”) on the VAT treatment of investment management services illustrate that this is still an area of some uncertainty that is continuing to evolve. The first decision,...more
On 22 January 2013, the Council of the European Union adopted a decision authorising eleven countries - Belgium, Germany, Estonia, Greece, Spain, France, Italy, Austria, Portugal, Slovenia and Slovakia — to proceed with the...more
Legal advice privilege has seized the focus of attention yet again, as a result of the UK Supreme Court’s decision in Prudential delivered on 23 January 2013. In overview, Prudential sought to withhold documents including...more
Draft clauses to introduce a new general anti-abuse rule (GAAR) into the UK tax code were published as part of the Finance Bill 2013 on 11 December 2012. Some form of general anti avoidance rule was first seriously canvassed...more
Following the execution of an inter-governmental agreement (or “IGA”) with the United States in September 2012 and a consultation exercise which closed in late 2012, HM Revenue & Customs (“HMRC”) recently published draft...more
Welcome to the Winter edition of Real World from Dechert’s London Finance and Real Estate Group, keeping you up to date with recent developments in real estate law and practice.
In this issue:
- An A-Z for 2013 – A...more