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International update for April

International update for April

Tim Sarson’s latest summary of international developments.

Tim Sarson

Partner and Brexit Tax & Location Lead

KPMG in the UK


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The European Commission’s state aid decision on the UK’s CFC finance company exemption should act as a trigger for groups which have made use of the exemption to consider the location of relevant significant people functions. Further work has been done at an OECD level around improving tax transparency, particularly in the area of beneficial ownership. The EU continues to promote anti-tax avoidance measures and the European Parliament has called for the introduction of even stricter rules. There are also noteworthy developments in transfer pricing, including the IRS embracing the use of data analytics in its APA programme.

In the latest of his regular articles for Tax Journal*, Tim Sarson rounds up recent international developments. This month’s article looks at:

  • The compatibility of the UK CFC rules with EU state aid rules;
  • Tax fraud, evasion and avoidance;
  • Transfer pricing; and
  • Digital services taxation.

* First published in Tax Journal on 26 April 2019. Reproduced with permission.

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