The EU Anti-Tax Avoidance Directive – Impact on Corporate Treasury

On 21 June 2016 the EU’s ministers of Finance and Economic Affairs, the so-called ECOFIN Council, unanimously approved the Anti-Tax Avoidance Directive (“ATAD”). This measure was originally proposed in January 2016 as part of the wider Anti-Tax Avoidance Package and was amended a number of times since its initial release.

Click HERE for a brief overview of some of the key changes agreed for implementation as part of the ATAD and in particular their relevance for corporate treasurers.

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Tackling Tax Avoidance in the EU – Impact on Corporate Treasury

Many corporate treasurers are likely to have become more aware of the OECD’s Base Erosion and Profit Shifting (BEPS) project, given the worldwide publicity it has received and the focus it has placed on limiting tax benefits of intragroup financing arrangements as a source of aggressive tax planning.

Following on from the BEPS project, the European Commission released its own draft anti-avoidance tax package on 28 January 2016 which contains measures to prevent aggressive tax planning, boost tax transparency and create ...

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BEPS Consultation

BEPS Action 4: Interest Deductions and Other Financial Payments

On 18 December 2014, the OECD, as part of its work on the Action Plan to address Base Erosion and Profit Shifting (BEPS), released a Public Discussion Draft on Action 4 in relation to the deductibility of interest expense and economically equivalent financing payments. The Discussion Draft outlines three main alternatives to address non-taxation through the use of interest deductions:

  • Deduction limitations based on group attributes
  • Deduction limitations based on fixed economic ratios and
  • Targeted ...
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Technical Update – OTC Derivatives Reform

European Market Infrastructure Regulations – June 2012

OTC Derivatives Reform

On 25th June, the European Securities and Markets Authority (ESMA) published its draft proposals for improving the functioning of the derivatives markets in the European Union. The European Markets Infrastructure Regulations (EMIR) aim to reduce risk through the use of sound and resilient central clearing firms, increase transparency through mandatory trade notification mechanisms and reduce counterparty risk through appropriate risk mitigation techniques.

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This members’ update is for general information only and ...

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Technical Update – Tax & Accounting – January 2012

Ernst & Young/Oxford Economics economic review for financial services for Winter 2012/2012

This report covers the main financial services areas, banking, insurance, asset management and has country forecasts for the major eurozone economies.  There is also an analysis of the proposed Financial Transactions Tax.
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Derivative Valuation

Recently, there has been an increase in the use of OIS as a basis for valuing derivatives in the financial markets.  Click here for a summary of the main strategic, operational and reporting  issues ...

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Technical Update: Tax

Changes to the rules on getting an Irish tax deduction for interest payments

What has happened?
Amid the somewhat chaotic passing of the Finance Act in January 2011, treasurers may have missed a provision that could have significant consequences for the tax deductibility of intra-group interest payments.

When income tax was introduced to Ireland in 1853 one of the main deductions was for interest on borrowings. Originally, all interest payments made by a person or a company were tax deductible. Older readers ...

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