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The Investec case returns to the Upper Tribunal for consideration of whether (and if so, how) taxed partnership profits have to be brought into the tax computation of the partners’ financial dealing trades. In A Ltd v Finland Insurance the CJEU confirms that premiums on contracts covering risks associated with cross-border company acquisitions should be taxed where the policyholder is located, not where the target is located. In Morgan Stanley, the CJEU rules on the input tax recovery of a French branch concluding that it is necessary to look through to the taxable activities of the UK head office. The government decides to align with EU law the VAT exemption for SIF management to provide certainty after the UK leaves the EU. Recent diverted profits tax developments are the December 2018 revised guidance and the launch of a new Profit Diversion Compliance Facility to encourage MNCs to reset their transfer pricing.
This article was first published in the 8 February 2019 edition of Tax Journal.