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Two weeks to 18 July 2019

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK

Finance Bill 2019-20

EU Mandatory Disclosure / DAC 6: consultation on UK draft regulations
We have been advised that the UK draft regulations and guidance will be published on 22 July 2019.  Keep up with developments by looking for updates on the EU Mandatory Disclosure Regime Hub on our Suite.

CIR - HMRC changes policy on treatment of 'held for sale' subsidiaries
If your group treats any subsidiary as 'held for sale' you'll find it challenging to prepare your Corporate Interest Restriction ('CIR') analysis.  The challenge arises because you're required to treat that subsidiary as a standalone company (or, if it has subsidiaries of its own, as the parent of its own separate CIR group) and the information you need to do that isn't readily available.  Having spoken to HMRC about those challenges, they've told us they'll only insist on this approach in certain circumstances and that guidance will be published on this change of policy soon. Read more.