The UK’s HM Revenue and Customs on March 26 confirmed that it has joined with tax authorities of five other nations to share information about how digital multinationals might be shifting profits to tax havens. HMRC said that information gleaned from the collaboration will assist in applying the new UK diverted profits . . .
The UK on January 13 released an updated schema and supporting documents for software developers working on the FATCA service . . .
Tax justice campaigner Richard Murphy has been appointed Professor of Practice in International Political Economy at City University London. Murphy will be teaching a course titled Economics in the Real World. See: Tax Research UK.
Fearghus Carruthers, head of tax at Shire Pharmaceuticals, has been added to the list of witnesses scheduled to testify at a December 8 UK House of Commons Public Accounts Committee hearing on the role of large accounting firms in multinational tax avoidance. Carruthers will join . . .
Dorsey & Whitney LLP, on May 7, announced that solicitor and chartered accountant, Michael Cashman, has joined the firm’s London office as a partner in the Tax Group. Cashman works on UK and international transactional tax matters. Release
Christian Aid has received a mixed feedback from its survey of the 100 largest companies on the London Stock Exchange regarding whether to the UK should adopt public CbC reporting. See: Christian Aid.
The UK’s HM Revenue and Customs, on March 30, released interim guidance on its new diverted profits tax, set to go into effect April 1. The guidance uses practical examples to explain . . .
The UK government has released regulations implementing automatic exchange of information under the European Union Revised Directive on Administrative Cooperation and under the Multilateral Competent Authority Agreement implementing the Common Reporting Standard. The regulations, released March 24, also make minor changes to existing rules implementing the UK’s FATCA agreement . . .
UK businesses must adjust their accounting for VAT on intragroup supplies of services beginning in 2016 to follow the European Court of Justice’s ruling in Skandia America, HMRC said in a policy briefing released February 10. . . .
HM Treasury’s David Gauke on October 3 said the UK does not support the the adoption of the nexus approach described the OECD’s interim report on harmful tax practices to determine if intellectual property regimes reward “substantial activities” . . .
Draft UK regulations released on October 3 under the Promoters of Tax Avoidance legislation in Finance Act 2014 exclude from the definition of “promoter” the . . .
As expected, the UK government on March 24 published Finance Bill 2015, including the final version of its controversial new diverted profits tax. Provisions granting HMRC power to issue regulations to introduce country-by-country reporting requirements for MNEs consistent with OECD guidance were also included in the. . .
Ireland may not support a proposal advanced by the UK and Germany to use a modified nexus approach to put limits on preferential intellectual property tax regimes under the OECD/G-20 base erosion profit shifting (BEPS) plan, Finance Minister Michael Noonan said December 2. The joint UK/German proposal, announced by the . . .
G20 finance ministers, in a communique released following their Sept. 20-21 meeting in Carins, Australia, have expressed approval of the progress made toward completion of the G20 OECD Base Erosion and Profit Shifting (BEPS) Action Plan and have committed to finalizing all action items by 2015. Further, the ministers endorsed the finalized global Common Reporting Standard for automatic exchange of tax information, committing to exchange of information by 2017 or end-2018, subject to the completion of legislative procedures. Communique. See also, G20 release, prior coverage of BEPS recommendations.
UK formally commits to country-by-country reporting template: The UK has agreed to implement the country-by-country reporting template provided for in the OECD/G20 BEPS recommendations, Financial Secretary to the Treasury David Gauke announced in a Sept. 20 release. See, UK release.
_____________
India disputes binding arbitration proposals in BEPS recommendations: In a Sept. 22 speech before the G20, India’s Minister of State for Finance expressed support for the OECD/G20 BEPS project but said that developing nations had “major concerns” with proposals to introduce binding arbitration into the mutual agreement procedure for tax treaties. See, speech of Smt. Nirmala Sitharaman, India Minister of State for Finance. See, related coverage.
_____________
The OECD and Global Forum announce mandate to assist developing nations with BEPS: The OECD and its Global Forum on Transparency and Exchange of Information announced on Sept. 22 that they have been mandated by the G20 to develop toolkits to support developing countries in addressing BEPS and to launch pilot projects to assist them to move towards automatic exchange of information. The OECD said it will report to the G20 Leaders in November on its plan to deepen the involvement of developing countries in the OECD/G20 BEPS project and ensure that their concerns are addressed. OECD release.
The UK’s HM Revenue and Customs (HMRC) on November 30 announced that it has changed its interpretation of the company residence tie breaker clause in the Jersey-UK tax treaty and in 15 other tax treaties that . . .
The UK on May 26 updated the schema and supporting documents for Foreign Account Tax Compliance Act (FATCA) software . . .
The European Court of Justice on February 3 ruled that a UK law that puts restrictions on the ability of group companies to offset gains with nonresident subsidiary losses is compatible with EU law, rejecting the European Commission’s claim that the law made it “virtually impossible” . . .
The European Court of Justice on November 13 ruled that UK legislation that immediately attributes gains made by non-resident closely held companies to participators of the companies that are UK residents is a restriction on the free movement of capital as defined . . .
UK clothing retailer Next owes additional £22.4m tax after a First-Tier Tribunal ruled the firm’s tax avoidance structure known as a rate-booster was artificial tax avoidance, the UK’ s . . .
The UK gained £1,137 (USD 1.7 billion) by successfully challenging multinational transfer pricing in fiscal year 2013–14, according to statistics released by HM Revenue and Customs on March 6. The goverment collected twice as much tax from transfer pricing . . .
The UK government will introduce a new “diverted profits tax” to ensure that multinational corporations pay the correct about of tax, British Chancellor of the Exchequer, George Osborne, announced December 3 in his Autumn Statement. The UK also released a consultation on hybrid mismatches, and Osborne reaffirmed the UK’s intention to introduce country-by-country reporting for . . .
The UK government on September 18 released a guide on automatic exchange of financial account information which focuses on the requirements of the OECD Common Reporting Standard (CRS) and . . .
The UK’s conservative party on July 8 unveiled its first budget of new the new term, proposing to reduce the 20 percent UK corporate income tax rate to 19 percent beginning April 2017 and to 18 percent . . .
The UK on May 28 released a tax information and impact note on UK regulations issued March 11 that amend the worldwide debt cap. the regulations prevent changes to accounting standards from disallowing certain financing costs for investment entities. See, Corporation tax: changes to the worldwide debt cap (WWDC) provisions.
Orrick, Herrington & Sutcliffe announced on October 7 that Edward Denny has joined the firm’s London tax practice group. Denny, who is formerly with Norton Rose Fulbright, focuses on mergers and acquisitions. Release
The UK government on October 22 launched public consultations on proposed rules designed to limit excessive corporate interest deductions and revise the country’s patent box regime. Both proposals respond to the OECD/G20 base erosion . . .
The UK, on December 10, released a draft Finance Bill modifying the taxation of the loan relationships and derivatives contracts. The bill updates the computation of profits and losses on these instruments and the detailed rules by which they are taxed. See: Corporation tax: modernising the taxation of corporate debt and derivative contracts
A joint proposal advanced by the UK and Germany that put limits on preferential intellectual property regimes has been adopted by the OECD Forum on Harmful Tax Practices (FHTP) as a new starting point for drafting guidance under Action 5 the base erosion profit shifting (BEPS) plan, UK Financial Secretary to the Treasury, David Gauke said December 2. Gauke said the UK/German proposal . . .
The UK’s HM Revenue and Customs on October 13 launched an online FATCA guide to assist UK financial institutions in registering and reporting financial information on behalf of their US customers in accordance with UK-US legislation. HMRC
The UK’s HM Revenue & Customs, on July 31, released draft implementing agreements and regulations for a common reporting standard for automatic exchange of information, and has requested stakeholder input . . .
Japan and the UK have exchanged notes on a new article on business profits under the Japan-UK tax treaty, the Japanese government announced July 22. New Article 7 introduces provisions concerning . . .
The UK and Senegal signed a tax treaty on February 26, the UK’s HM Revenue and Customs has announced. Under the agreement, taxation in the source country on dividends is 5 percent for corporate shareholders that hold at least a 25 percent interest in the company paying the dividends, is 8 percent if the beneficial owner is a pension scheme established in source country, and is 10 percent in other . . .
The UK and Algeria signed a tax treaty on February 18 which provides for maximum rates of withholding tax for interest and royalty payments of 7 percent and 10 percent respectively, UK’s HM Revenue and Customs has announced. The treaty also provides for withholding taxes for dividends of 5 percent . . .
The UK’s HMRC on January 30 published a consultation paper entitled “Strengthening Sanctions for Tax Avoidance,” setting out proposals to address the serial use of tax avoidance schemes and proposing to introduce additional penalties . . .
The UK government on January 8 published a bill that would give Northern Ireland the power to set its own corporation tax rate beginning April 2017. If the bill is passed, it is expected that Northern Ireland will lower its . . .
The Isle of Man on December 15 published revised Guidance Notes relating to intergovernmental agreements to improve international tax compliance signed in 2013 with the UK and US. Release.
Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.
