Taxation of the digital economy: where are we and where are we going?
The digital economy has been the subject of much debate in recent years and in November 2017 the government published a ...
International Tax
International Tax
Base Erosion and Profit Shifting (BEPS): CIOT responds to recent OECD work
BEPS Action 7 – Attribution of Profits to PEs The OECD’s Discussion Draft on Additional Guidance on Attribution of Prof...
Finance (No 2) Bill 2017
On 13 July 2017, the government announced that the ‘Summer’ Finance Bill would not be published until September, however...
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EU Disclosure Rules
On 21 June 2017 the European Commission published its proposal in relation to the introduction of Europe wide mandatory ...
BEPS Action 8: Transfer pricing in relation to Hard-to-Value Intangibles
In May the OECD published draft implementation guidance for consultation which is intended to assist with the implementa...
Hybrids and other mismatch rules – HMRC guidance
The CIOT has written to HMRC to express concern about the use of guidance as a substitute for clear, well targeted legis...
Non-resident companies subject to income tax and non-resident CGT
The consultation document states that the proposals are largely driven by the aim of achieving consistency of treatment ...
Draft FB 2017 Cl 21: Corporate interest restriction
Revised draft legislation for implementing the proposed new rules on corporate interest restriction, which are intended ...
Scotland update – call for evidence on Scotland’s relationship with the EU
The European and External Relations Committee of the Scottish Parliament issued a call for written evidence (tinyurl.com...
Secondary adjustments to transfer pricing legislation
In our response to the consultation document published in May (Introduction of Secondary Adjustments into the UK’s Domes...