International Tax

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.

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.

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.

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.