Tackling Base Erosion and Profit Shifting is an important objective for government, and one supported by CIOT. However the legislation introducing new rules to tax income from intangible property held in low-tax jurisdictions is disproportionate, flawed and too broadly drawn. CIOT is engaging with HMT/HMRC in relation to the significant work that is required to ensure that this legislation reflects the stated policy aims.
As you might expect from the press coverage and public debate in recent years around large multinational groups, particularly those involved in the digital space, but not exclusively, and whether or not they are paying a ‘fair’ amount of tax, the International Taxes Sub-Committee of the CIOT has been busy.
HMRC have responded to requests by the ATT and CIOT for more guidance on compliance obligations which apply to all companies (regardless of size) looking to set off carried forward losses from April 2017.
CIOT has responded to the OECD’s Public Discussion Draft on transfer pricing for financial transactions, continuing the work of the G20/OECD’s BEPS project under Actions 8 to 10 with the mandate to ‘Align transfer pricing outcomes with value creation’.
With the growing number and variety of cryptoassets such as cryptocurrencies and digital tokens, the tax treatment can be complex and there is increasing need for clear guidance on the tax and accounting issues.
The CIOT, LITRG and ATT have responded to the Treasury Committee’s wide-ranging Inquiry into VAT and its Sub-Committee’s Inquiry into The conduct of tax enquiries and the resolution of tax disputes. In addition to our written responses we have also given oral evidence to the Committees