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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
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.
Corporate re‑domiciliation: CIOT response to government consultation
CIOT responds to government consultation on a new corporate re-domiciliation regime, suggesting that such a regime would be helpful for business, but that to be successful it must be straig
OECD BEPS Project – latest round of stakeholder input
The latest (and final?) round of OECD discussion drafts for public comment on the BEPS project were released in May and June.
OECD BEPS project – CIOT responds to recent consultations
The CIOT has responded to two recent discussion documents published by the OECD on BEPS actions.
UK government goes it alone on BEPS
The government announced at the autumn statement that it was introducing a new tax aimed at ‘large multinational enterprises with business activities in the UK who enter into contrived arrangements
