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See who has done the tax work on this month’s biggest deals

The OECD's base erosion and profit shifting (BEPS) project is well underway with proposals (at least in draft form) and consultations on all specific action points.

Tim Stewart

Timothy Lyons QC and Kelly Stricklin-Coutinho of 39 Essex Chambers analyse recent transparency developments across Europe, focusing on the proposed requirement for EU member states to provide a quarterly report on all cross-border tax rulings and advance pricing arrangements.

May’s instalment of his column sees Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, look at the problems that may arise for taxpayers given the timing differences applicable for different documentation and reporting requirements, and what options are available for reconciling these.

A $6.4 billion bill has landed on taxpayers’ MATs A seemingly positive exemption on Indian minimum alternative tax (MAT) for foreign portfolio investors turned sour when Prime Minister Narendra Modi announced back-taxes of more than $6.4 billion on 100 foreign investors into India, with thousands more still at risk. The announcement has caused some investors to decry the government's promises of a taxpayer-friendly regime. In his Budget speech in February, Finance Minister Arun Jaitley announced that foreign investors would be MAT exempt from April 1 2015, though did not immediately make clear that investors would face tax bills on transactions before this date. Amid earlier concerns about tax liabilities, the Indian government assured foreign investors they would not be liable for the tax, which was introduced for the sole purpose of taxing domestic Indian companies. However, asset managers and other investors are now worried that tax demands from the Indian authorities will soon be landing on their desks.

Partho Shome’s 30-year career as a tax official and adviser to Indian governments and multilateral organisations may be at an end for now, but he will still take a keen interest in tax policy, as this exclusive interview with International Tax Review reveals.

Bob van der Made With the fight against aggressive tax planning, tax fraud, tax avoidance and tax evasion having become a policy priority for the EU, the European Parliament is upping the ante in the heated debate on tax rulings and calls for more tax transparency. On February 12 2015, the European Parliament decided to set up a special committee on tax rulings and other measures similar in nature or effect (TAXE) "to examine practice in the application of EU state aid and taxation law in relation to tax rulings and other measures similar in nature or effect issued by member states, if such practice appears to be the act of a member state or the Commission". The special committee's mandate is therefore to analyse and examine how EU state aid rules have been applied by the Commission to tax rulings in member states since January 1 1991 (this seems inspired by the Commission's ongoing state aid investigation into Apple; otherwise this date seems arbitrary), and member states' compliance with the EU's directives on mutual assistance (1977) and on administrative cooperation in tax matters (2011), in particular with regard to the spontaneous exchange of information on tax rulings. It should be noted, however, that member states are only effectively obliged to spontaneously exchange information on cross-border tax rulings under certain circumstances under the EU Directive on administrative cooperation in tax matters since 2013. According to the Commission's statistics, member states haven't actually really done this in practice, however.

Carrie Aiken

Loreto Pelegrí