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Taxation of the digital economy: where are we and where are we going?
The digital economy has been the subject of much debate in recent years and in November 2017 the government published a position paper on Corporate tax and the digital economy. The g
OECD: Mandatory disclosure rules for addressing CRS avoidance arrangements
The OECD published its paper in response to the Bari Declaration issued by the G7 Finance Ministers in May 2017, and in the light of information on offshore tax planning released by media organisat
Base Erosion and Profit Shifting (BEPS): CIOT responds to recent OECD work
BEPS Action 7 – Attribution of Profits to PEs
The OECD’s Discussion Draft on Additional Guidance on Attribution of Profits to PEs largely adopts the approach of setting the high-level gen
Finance (No 2) Bill 2017
On 13 July 2017, the government announced that the ‘Summer’ Finance Bill would not be published until September, however, they also provided some information about the content of the Bill and when
EU Disclosure Rules
On 21 June 2017 the European Commission published its proposal in relation to the introduction of Europe wide mandatory disclosure rules and effective disincentives for tax advisers that design or
BEPS Action 8: Transfer pricing in relation to Hard-to-Value Intangibles
In May the OECD published draft implementation guidance for consultation which is intended to assist with the implementation of the principles arising from the work done through Action 8 of the BEP
Non-resident companies subject to income tax and non-resident CGT
The consultation document states that the proposals are largely driven by the aim of achieving consistency of treatment with regard to income from UK real property between UK resident companies (al
Hybrids and other mismatch rules – HMRC guidance
The CIOT has written to HMRC to express concern about the use of guidance as a substitute for clear, well targeted legislation in light of the draft guidance (which will form part of the internatio
Draft FB 2017 Cl 21: Corporate interest restriction
Revised draft legislation for implementing the proposed new rules on corporate interest restriction, which are intended to form part of the Finance Bill 2017, was published on 26 January 2017.
