HMRC has published draft guidance on one of the Controlled Foreign Companies (CFC) changes in the Finance Bill. The CJEU (Court of Justice of the European Union) has rejected the UK government’s legal challenge to the proposed financial transaction tax on procedural grounds. The political will to proceed with this initiative is continuing.
The European Commission’s proposed amendment to the EU Parent-Subsidiary Directive regarding hybrid loans has been blocked by Sweden, but discussions relating to obtaining agreement shortly continue. A recent case in India highlights the risk of creating a permanent establishment when sending employees to India on secondment. Draft guidance on the German corporate tax loss limitation rules has been published.