Source: Smart & Biggar/Fetherstonhaugh via International Law Office 31 July 2017
“The Federal Court has issued its further judgment and reasons (2017 FC 637) concerning the amount of financial compensation to be paid to Dow Chemical Company as a result of earlier patent infringement and validity proceedings against NOVA Chemicals Corporation (for further details please see “Dow succeeds on major issues in patent infringement profits case“).
The final award totals over C$645 million (including pre-judgment interest), which is the largest reported award in a Canadian patent infringement case.”
Source: Deloitte Global Transfer Pricing Alert 2017-033
“The first country-by-country (CbC) reporting notifications required to be made to the UK tax authorities are due by 1 September 2017.
This deadline applies to all reporting periods that end on or before 1 September 2017.
After 1 September 2017, the standard UK notification date is the end of the CbC reporting period.
A few examples regarding the application of these rules follow.
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EBTs – “Going forward, it is unlikely that any assessments to tax they (HMRC) issue will be anywhere near as generous as was previously available”
Source: Ogier via mondaq 23 July 2017
“HMRC’s successful appeal against the owners of the now-liquidated Glasgow Rangers FC is likely to lead to further challenges against Employee Benefit Trusts (EBT) and other loan and benefit schemes that have not yet gone through the settlement process, says Employee Incentives specialist Katherine Neal of Ogier.”
Source: Crowe Clark Whitehill via Mondaq, 18 July 2017
“There has been much debate about whether Brexit will have a positive or negative impact on the UK’s international trade. For many, leaving the EU presents many questions to which the answers are unclear. But, in the continuous mist of uncertainty there could be a potential bright side to Brexit, where international trade zones are concerned, in the form of Free Trade Zones.”
“Free Trade Zones are widely used across the world, particularly in the US, South America, Canada, Middle East and Asia. The precise format varies, but it is very common for governments to use Free Trade Zones to encourage local manufacturing. They can also be used to simplify, or remove, import and local tax obligations for goods that are imported into the zones for manufacturing or processing.”
Robert Marchant, of Crowe Clark Whitehill, says “Clearly, the establishment of Free Trade Zones themselves will only help the UK economy if the port infrastructure is in place to support and assist UK manufacturers. A quick internet search shows that the UK is one of Europe’s biggest importers and exporters and my clients tell me that the UK has excellent port facilities; which suggests that the infrastructure is in place and could therefore be a platform for the creation of UK Free Trade Zones.”