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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
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On 13 July 2017, the government announced that the ‘Summer’ Finance Bill would not be published until September, however, they also provided some information about the content of the Bill and when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
