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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
Transfer pricing: BEPS Actions 8–10 Financial Transactions
In July 2018 the OECD published a non-consensus discussion draft on transfer pricing for financial transactions under the mandate of the Report on Actions 8-10 of the BEPS Action Plan (Aligning tra
Tax avoidance involving profit fragmentation
HMRC launched a consultation titled Tax avoidance involving profit fragmentation on 10 April 2018.
Digitalised economy: recent consultations and developments
On 13 March 2018, the UK government published an updated position paper setting out its views on Corporate tax and the digital economy.
Royalties withholding tax: CIOT responds to consultation
The digital economy was identified as an action point of the G20/OECD BEPS project in 2013 and the CIOT has engaged with the OECD and the EU Commission, as well as with the UK government since then
