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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
Hybrids and other mismatch rules
At Spring Budget 2020, the government published a consultation document which examined the impact of the double deduction rules and the acting together rules within the hybrid and other mis
Expansion of the Trust Register: consultation responses
The ATT and CIOT have both responded to HMRC and HM Treasury’s technical consultation on the Fifth Money Laundering Directive and Trust Registration Service.
Addressing the tax challenges of digitalisation of the economy
The CIOT has responded to the second consultation published by the OECD on addressing the tax challenges arising from the digitalisation of the economy which focuses on Pillar Two and sets
Review of Double Taxation Treaties 2019/20: CIOT responds to the Stakeholder Consultation
Every year HMRC undertakes a review of the priorities for the UK’s network of double taxation agreements for the coming year and invites stakeholders to input into this.
Addressing the tax challenges of the digitalisation of the economy
The tax challenges arising from the digitalisation of the economy were identified as one of the main areas of focus of the Base Erosion and Profit Shifting (BEPS) Action Plan, becoming known as BEP
