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Base Erosion & Profit Shifting ("BEPS")

Profit Fragmentation Rules

Profit Fragmentation Rules Introduction – Profit Fragmentation Rules This has been billed as the new Diverted Profits Tax (“DPT”) for individuals, partners and SMEs. As such, covering the gaps in 

EU Tax Avoidance Directive – DAC6

EU tax avoidance directive – DAC6 – HMRC, Hallmarks, CRS & MDR Background Both the Panama & Paradise Papers have acted as a shot in the arm for those calling 

Luxembourg is first EU country to impose specific reporting requirements in relation to EU blacklisted jurisdictions.

Luxembourg is the first country to officially introduce reporting requirements for Luxembourg companies who transact with jurisdictions designated by the European Union as ‘non-cooperative’ for tax purposes. The measures, which 

Related Party Transactions – Transfer Pricing Disclosure and Documentation

What is transfer pricing? Transfer pricing is one of the most important issues in international tax. Transfer pricing is the general term for the pricing of cross‐border, intra‐firm transactions between 

Demystifying BEPS – Base Erosion and Profit Shifting

What is BEPS? In recent months, HMRC has been actively involved in the implementation of the Base Erosion and Profit Shifting (BEPS) ideas into the British tax system. It is 

Tax anti-avoidance: Draft directive agreed by EU

General It seems fitting that today, as the polls open and the UK heads out to make their decision on the UK’s membership of the EU ‘club’, the European Council 

Budget 2016: Royal(ty) blood? Withholding tax on royalty payments

Background It was announced at the Budget that withholding tax (WHT) will apply to most royalty payments from later this year. As one might expect, there are also additional measures 


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