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In this issue:

Focus Feature

  • Brexit: what will be the tax impact for the UK and Europe?

Legal Developments


  • Implementing BEPS Action 13


  • Commission uses State Aid to challenge rulings given under the Belgian "Excess profits" regime
  • Debt waiver granted to a foreign subsidiary: tax treatment in the beneficiary's state is not relevant
  • Financial compensation for financial activities: must a group cash pooling entity apply a margin to loans granted to related entities?


  • Tax changes in new draft Bill will affect multinational and cross-border taxation


  • Hungary adopts new rules on the taxation of IP rights


  • General Anti-Avoidance Rule enters into force on 15 July


  • Extended limitation period for audits of tax credits and net operating losses carried forward
  • Is default interest deductible from Corporate Income Tax?

United Kingdom

  • Good news and bad news: UK reforms its rules on carried forward losses
  • Adjusting for the future: new transfer pricing rules could affect finance and royalty structures
  • Behind the veil: corporate transparency in the UK
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