International Tax

Technical
1 November 2017

The CIOT has submitted comments to the OECD in response to its recent Discussion Draft on BEPS Action 7 – Additional Guidance on Attribution of Profits to Permanent Establishments (PEs) and Request for Input on Work regarding the Tax Challenges of the Digitalised Economy.

Technical

The CIOT commented on the draft legislation published in July 2017 in relation to non-doms and substantial shareholding exemption (SSE); these provisions are now incorporated into Finance (No 2) Bill 2017 published on 8 September 2017. In addition, the draft legislation published in July reflected a change that the CIOT had recommended in relation to hybrid mismatch arrangements. The Finance (No 2) Bill 2017 also reflects a change to SSE rules which addresses the concern we raised.

Technical
1 September 2017

Drawing on our experience in the UK of our Disclosure of Tax Avoidance Schemes (DOTAS) rules, the CIOT has contributed to an Opinion Statement prepared by the Confédération Fiscale Européenne (CFE), the European association of tax advisers, on the European Commission’s proposal to introduce Europe wide mandatory disclosure rules and effective disincentives for tax intermediaries (including advisers) that design or sell potentially harmful tax schemes.

Technical
1 August 2017

The CIOT commented on the Public Discussion Draft on Base Erosion and Profit Shifting (BEPS) Action 8 – Implementation Guidance on Hard-to-Value Intangibles published by the OECD in May 2017.

Technical
1 July 2017

The CIOT has challenged HMRC over its view on the application of the legislation to state and local taxes, saying that the draft guidance does not reflect the legislation, existing case law or the overarching policy behind the hybrid mismatch rules. HMRC’s view is also inconsistent with existing legislation and practice on double tax relief and the UK’s various treaty obligations.

Technial
1 July 2017

In March 2017 the government published a consultation document which considers proposals to bring non-resident companies within the charge to corporation tax in respect of income arising from UK real property and also gains which are currently taxed as non-resident CGT gains (NRCGT gains). The CIOT commented that we would prefer to see a strategic review of property taxation and that further work should be done on the Exchequer and economic impact of the proposals before any decision is taken.

Technical
1 March 2017

In addition to raising concerns around some aspects of the detail of the proposed new rules, the CIOT tackled the implementation of the new rules for a corporate interest restriction, saying that the legislation has been rushed through without sufficient time for full consideration.

Technical
1 October 2016

The CIOT responded to a call for evidence issued by the European and External Relations Committee of the Scottish Parliament, called to support its inquiry into the implications for Scotland’s relationship with the EU after the referendum on 23 June.

Technical
1 October 2016

The CIOT has told the government that secondary adjustments should not be introduced into the UK’s domestic transfer pricing legislation.

ADIT Voice
7 September 2016

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