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International update for May

International update for May

Tim Sarson’s latest summary of international developments.

Tim Sarson

Partner, Value Chain Management

KPMG in the UK


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Cooperative compliance programmes are becoming increasingly en vogue: the early signs are that HMRC’s profit diversion compliance facility has been a success; and Italy has introduced a new cooperative compliance programme for ascertaining permanent establishment (PE) status targeted at large multinationals. The Crown dependencies have jointly issued long-awaited draft guidance notes on the economic substance requirements which came into force from the beginning of 2018. The latest incarnation of Swiss tax reform passed a public vote and will come into effect from 1 January 2020. A public consultation has begun on proposed amendments to the profit attribution rules for PEs in India. France and the Czech Republic have continued to drive forward with unilateral measures on digital taxation.

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

  • UK’s profit diversion compliance facility;
  • Italian cooperation compliance programme for PE status as well as economic growth measures;
  • Economic substance requirements in Crown dependencies;
  • Swiss tax reform;
  • Indian profit attribution rules for PEs;
  • Greek, Cypriot and US updates; and
  • Developments in the taxation of the digital economy.

* First published in Tax Journal on 31 May 2019. Reproduced with permission.

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