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Double tax treaties: review of treaty policy positions
In July 2022, HMRC’s Tax Treaty Team sought input in relation to the changes to Article 5 of the OECD Model Tax Convention (MTC) as a result of the BEPS action reports and also in relation to the p
The two-pillar solution to international tax: where we are now?
In October 2021, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) reached an agreement on a two-pillar solution to reform the international tax framework in response to the challenges
Termination Packages – Is a complete tax and NI exemption due?
The tax treatment of termination packages is complex. Tax and National Insurance (NI) exemptions are often available in respect of some, or all, of the package.
The Global Anti-Base Erosion Model Rules (Pillar 2): CIOT responses
In October 2021, the OECD/G20 Inclusive Framework on BEPS reached an agreement on a two-pillar solution to reform the international tax framework in response to the challenges of digitalisation.
Homeworking and hybrid working – the employment tax considerations
The coronavirus pandemic has significantly changed the way we work. Homeworking has become the norm for employees who previously spent all or almost all of their time in offices.
Off-payroll working rules – what do we mean by a ‘managed service’
The reforms to the off-payroll working rules (IR35) were initially rolled out to the public sector in 2017 with the intention of allowing allow government bodies time to put their own house in orde
Chain, Chain, Chain (of Supply): Due Diligence of Labour Supply Chains
The extension of the IR35 rules to the private sector with effect from 6 April 2021 has highlighted the need to undertake due diligence on labour supply chains.
Umbrella companies – why labour supply chain due diligence is essential
With the rise of flexible working, partly in response to changes in tax and employment law legislation, there have been changes in how organisations are resourcing their people.
