Tax New Highlights: November 2022

In this podcast, Zoe Andrews and Tanja Velling discuss the CJEU’s decision in Fiat on fiscal State aid and the Supreme Court’s decision in NHS Lothian on historic claims for input tax recovery. They also discuss UK Finance’s report on the total tax contribution of the UK banking sector, the designation of the 2022 edition of the OECD’s Transfer Pricing Guidelines under TIOPA and the removal of the expiry date for the regulatory capital exemption from the UK’s anti-hybrid rules.

The podcast covers the OECD’s “Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One” and its report on “Tax Incentives and the Global Minimum Corporate Tax” as well as the Public Accounts Committee’s inquiry into the UK’s digital services tax. Zoe and Tanja also discuss the recent signature of two separate multilateral competent authority agreements on the automatic exchange of, respectively, information reported by digital platform operators on their sellers and information reported by intermediaries (or, in certain circumstances, taxpayers) in relation to arrangements intended to circumvent the Common Reporting Standard or structures that disguise the beneficial ownership of assets, in each case in the context of existing or proposed UK regulations on the topic.