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Content Type: Publications Tagged: 'David Harkness'

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Look out – why new EU tax reporting requirements are ahead!

7 June 2018


New EU rules - commonly known as "DAC 6" - under the Directive on Administrative Cooperation require taxpayers and intermediaries to report a wide range of transactions to their home tax authorities. In some cases these are transactions that are tax-motivated....

US Tax Reform: Who comes out ahead?

21 December 2017


On December 20, 2017, Congress voted to enact the most sweeping US tax reform bill in decades. The Tax Cuts and Jobs Act will reduce business tax rates and revamp the US international tax system. While the President may not sign the Act until January 2018,...

Can the UK CFC rules survive the EC’s state aid investigation?

20 November 2017


The UK’s current CFC rules were created in the light of decisions of the CJEU and EFTA Court, which suggested that in most cases involving EEA subsidiaries it will be unlawful for the then existing CFC rules to apply at all. However, the European Commission...

European Commission takes aim at UK CFC tax regime

1 November 2017


The European Commission has opened an in-depth State aid probe into the group financing exemption under the UK's Controlled Foreign Companies (CFC) rules. An adverse finding at the end of the investigation, even if after the date of Brexit, could lead to the...