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On 26 March 2025, in a published paper the CIOT set out concerns about the potentially unforeseen tax implications for non-UK domiciliaries who make remittances on or after 6 April 2025, having

The annual review of the UK’s double tax treaty network provides stakeholders with an opportunity to input into HMRC’s review of the priorities for the UK’s network of double taxation agreements fo

The CIOT responded to the call for evidence on offshore anti-avoidance legislation by suggesting that an entirely fresh anti-avoidance code be drawn up.

Clauses 19 to 22 of the Finance Bill 2024-25 make changes to various international tax aspects of the UK tax code.

On 18 November 2024, HMRC convened a meeting of representatives from several professional bodies, including the CIOT, to discuss and seek feedback on the construction of the draft legislation conce

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

On 13 July 2017, the government announced that the ‘Summer’ Finance Bill would not be published until September, however, they also provided some information about the content of the Bill and when

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

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

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