Amount B of Pillar One: OECD consultation
The OECD published a consultation on Amount B of Pillar One in July 2023.
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Reform of transfer pricing, permanent establishments and diverted profits tax
The government said in April 2023 that it would consult on updating the UK’s legislation on transfer pricing, permanent establishments and diverted profits tax.
OECD continues its work in developing the two-pillar solution
In December 2022, the OECD published a number of consultation documents in relation to the two-pillar solution to reform international tax agreed by the OECD/G20 Inclusive Framework on BEPS to deal
New gig economy reporting rules
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Very broadly, the Organisation for Economic Co-operation and Development’s (OECD) model reporting rules for digital platforms will require UK platform oper
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