Financial Services Tax Talking Points 2007 International Tax News

Welcome to the latest edition of Financial Services Tax Talking Points 2007 – International Tax News, a regular newsletter for our financial services clients dedicated to international tax developments. This publication is designed to keep you abreast of the latest technical developments and issues relevant to your business and provides up-to-date comment from our global network of tax professionals who will share their experiences, views and analysis.

In this issue:

• HMRC Proposals Regarding Interest Deductions - Part I – The Taxation of the Foreign Profits of Companies discussion document, published by HMRC in June, sets out a package of proposals for discussion with business and business advisers. The aim of the discussion document is to develop more detailed proposals for further discussion ….
• Intra-Group Lending: Post Prudential – The recent decision by the Special Commissioners in Prudential plc and the Commissioners for Her Majesty’s Revenue and Customs [SpC636] (‘Prudential’) has generated considerable interest in the financial services market. It is the first time the UK courts have been asked to decide on the application of an ‘unallowable purpose’ test ….
• HMRC Final Guidance on Indofood – HMRC has recently issued its final guidance in respect of Indofood International Finance Ltd v JP Morgan Chase Bank NA London Branch (‘Indofood’) ….
• Focus on: Luxembourg and the Netherlands – This article examines new regimes for investment funds in Luxembourg and the Netherlands and how these regimes might prove to be attractive options for hedge fund managers. Both regimes provide on-shore investment funds, with the option to have regulated funds which might be subject to less onerous regulatory restrictions and oversight ….
• Global Update - update on international markets.

To read the articles in full, download International Tax News 736Kb Dec 2007

Previous issues:

• June 2007 1.3Mb Jun 2007
• September 2007 593Kb Sept 2007