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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
Non-resident CGT: UK Property Rich Collective Investment Vehicles – draft regulations
Finance Act 2019 introduced new provisions further extending the taxation of gains accruing to non-UK residents on UK property.
Digital services tax: draft Finance Bill
It was announced at Budget 2018 that the UK would implement a DST, and the government subsequently consulted on the proposed tax.
Offshore receipts in respect of intangible property: draft regulations and guidance
The CIOT has commented on the draft regulations (and explanatory note) which will make amendments to the rules taxing Offshore Receipts in respect of Intangible Property (ORIP) now contained in a n
Tax and the digitalised economy
In the Budget 2018, the government announced that it would introduce a UK digital services tax (DST) from April 2020; a consultation document followed.
The Inheritance Tax Account forms (IHT100) Project
The collection of Inheritance Tax Account (IHT100) forms, together with various supplementary pages, are used to tell HMRC about chargeable events when inheritance tax (IHT) is payable on a trust o
