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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 documentation – a consultation: CIOT response
In our response, we note that the current requirements around transfer pricing documentation are being looked at due to the passage of time since the government adopted the minimum standard relatin
DAC6 guidance for CIOT and ATT members and students
We have recently published guidance on our websites to help our members and students understand when they might be classified as an ‘intermediary’ under the UK’s regulations which bring int
Hybrid and other mismatches regime: proposed changes
The CIOT welcomed the changes to the hybrid and other mismatches regime for corporation tax announced by the government in November 2020, but sought further clarification around some of the changes
OECD Blueprints for Pillars One and Two to address the challenges of digitalisation of the economy: CIOT response
The CIOT responded to the reports published by the OECD on the Blueprints for Pillar One and Pillar Two, the proposals by the Inclusive Framework to address the challenges of the digitali
Double taxation treaties stakeholder review 2020/21: CIOT input
The CIOT have taken part in HMRC’s stakeholder consultation seeking input into their annual review of the priorities for the UK’s network of double taxation agreements for the coming year.
