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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
Secondary adjustments to transfer pricing legislation
In our response to the consultation document published in May (Introduction of Secondary Adjustments into the UK’s Domestic Transfer Pricing Legislation) on whether secondary adjustments should be
Scotland update – call for evidence on Scotland’s relationship with the EU
The European and External Relations Committee of the Scottish Parliament issued a call for written evidence (tinyurl.com/j7nkvhm) at the start of August to support its inquiry into the implications
Tax deductibility of corporate interest expense
In our response to the second consultation on Tax Deductibility of Corporate Interest Expense, the CIOT said that the mooted start date of April 2017 was too ambitious given the scale and
Finance Bill 2016 cl 62 – hybrid and other mismatches
The CIOT wrote to HMRC about the new Pt 6A Taxation (International and Other Provisions) Act 2010 (TIOPA 2010), which will be inserted by FB 2016 cl 62 and Sch 10.