In this podcast, Zoe Andrews and Tanja Velling are joined by Nele Dhondt to discuss the EU’s Foreign Subsidies Regulation, how it could apply in the tax context and what steps can be taken to prepare for its coming into force. They also discuss the Advocate General’s opinion in the Amazon State aid case, recommending that the Court of Justice upholds the General Court’s decision that had annulled the European Commission’s finding of State aid.

In relation to the UK, the podcast considers HMRC’s draft guidance on the multinational top-up tax (the first tranche of which has been published for consultation until 12 September) and HMRC’s updated guidance on the loan relationships unallowable purpose test.

Zoe and Tanja also discuss the consultation on the reform of the UK’s transfer pricing, permanent establishment and Diverted Profits Tax legislation, the announcement of the “Energy Security Investment Mechanism” which should effectively bring forward the end date of the Energy (Oil and Gas) Profits Levy if oil and gas prices fall below certain thresholds, and the Upper Tribunal’s decision in Hargreaves Property Holdings on interest withholding tax.