Europe

Europe

Irish tax proposal will not eliminate “double Irish,” say attorneys

October 24, 2014

Even if Ireland eliminates the Irish incorporated non-resident company, as proposed in 2015 Irish budget, the tax benefits of the “double Irish Dutch sandwich,”can still be achieved by setting up a Irish company managed and controlled in Malta or the UAE instead of a Caribbean nation because of provisions in Ireland’s existing tax treaties with those nations, writes Jeffrey L. Rubinger and Summer Ayers LePree of Bilzin Sumberg Baena Price & Axelrod LLP in an October 23 website post. See, Bilzin Sumberg.

Multinational

UK/German compromise on IP regimes should be extended to activities not patentable, Netherlands official says

December 8, 2014

The Netherlands State Secretary of Finance on December 1 expressed support for a UK/German agreement to put limits on preferential intellectual property tax regimes under the OECD/G-20 base erosion profit shifting plan, but said that incentives should not be limited to activities that are legally protected, such as by patent, writes EY in a December 5 tax alert. The Netherlands does not plan major revisions to its innovation box regime, EY reported. For discussion, See EY.

Europe

EU Commission proposes automatic exchange of tax ruling info, weighs public release of country-by-country reporting data

March 18, 2015

The European Commission on March 18 released a proposal that would require EU states to automatically exchange information about their tax rulings with other EU states. The Commission also announced plans to study the possibility of imposing greater tax transparency requirements on companies operating in the EU. The proposal, first announced by EU Commission President . . .

Europe

Germany, UK agree to limits on patent box

November 10, 2014

The UK and Germany have agreed to a joint proposal on harmful tax practices which limits the patent box tax break, writes Reuters, quoting unnamed German government officials. The countries will present the proposal to the OECD Forum on Harmful Tax Practices. For details, see Reuters.

Europe

HMRC publishes draft guidance on proposed CFC amendments

April 17, 2014

The U.K.’ s HM Revenue and Customs, on April 17, published draft guidance for proposed additions to the controlled foreign companies (CFC) rules in Part 9A TIOPA 2010, clause 286 of Finance Bill 2014. The guidance concerns new provisions that would switch off the full or partial exemption rules for loan relationship credits of a CFC where there is a main purpose of transferring profits from existing intra-group lending out of the U.K. Draft guidance (PDF 77K)