International Tax

Technical
1 January 2019

Legislation introducing an anti-profit fragmentation rule incorporates a number of improvements on the previous draft legislation and original consultation proposals.

Technical
1 January 2019

Tackling Base Erosion and Profit Shifting is an important objective for government, and one supported by CIOT. However the legislation introducing new rules to tax income from intangible property held in low-tax jurisdictions is disproportionate, flawed and too broadly drawn. CIOT is engaging with HMT/HMRC in relation to the significant work that is required to ensure that this legislation reflects the stated policy aims.

Technical
1 October 2018

CIOT has responded to the OECD’s Public Discussion Draft on transfer pricing for financial transactions, continuing the work of the G20/OECD’s BEPS project under Actions 8 to 10 with the mandate to ‘Align transfer pricing outcomes with value creation’.

Technical

The ATT and CIOT have responded to a consultation on proposals to tackle avoidance schemes where profits of trades or professions are moved outside the charge to UK tax.

Technical
1 June 2018

Spring saw a number of announcements relating to the taxation of the digitalised economy. The CIOT remains engaged with the debate on which governments and the international tax community are firmly focused.

Technical
1 April 2018

On 28 February 2018, HMRC launched a digital portal for the corporate interest restriction (CIR) aimed at enabling taxpayers to appoint a reporting company and for the reporting company to be able to submit an interest restriction return. Companies can use this portal by logging on with the same credentials that are used to complete their corporation tax return.

Technical
1 April 2018

Following an announcement at the Autumn Budget, the government published a consultation document on Royalties Withholding Tax on 1 December 2017. Following a meeting with HMRC and HMT, the CIOT responded to these proposals, reiterating our view that, following the US tax reforms, which occurred after the announcement, the proposed measures would not raise any significant revenue for the Exchequer, but would result in significant costs for HMRC (as well as taxpayers) in terms of compliance.

Technical
1 March 2018

The CIOT has responded to the OECD’s recent public discussion draft paper on Mandatory disclosure rules for addressing common reporting standard (CRS) avoidance arrangements and offshore structures.

Technical
1 March 2018

The CIOT has engaged with the government in the ongoing debate about taxation of the digital economy following the publication of a position paper on the digital economy and an autumn Budget proposal for a new royalty withholding 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.