United Kingdom–MNE Tax

Europe

UK policy paper discusses plan to give HMRC power to issue regulations requiring digital platforms to report information about sellers’ income: HM Revenue and Customs→

March 3, 2021

G7 leaders reaffirm commitment to reach international tax agreement

February 23, 2021

G7 leaders reaffirmed their commitment on February 19 to reach an agreement by mid-2021 on new international tax rules. During a first leaders’ meeting under the UK’s G7 presidency, the Group of Seven resolved to . . .

Austria

Trade groups sue over Maryland’s controversial tax on digital advertising

February 22, 2021

Four organizations have joined in a lawsuit challenging a new Maryland state law levying a tax on digital ad revenue – the latest twist in an ongoing dispute with international implications. The US Chamber of Commerce, the . . .

Americas

Report estimates effective tax rates on investment in the EU member states, North Macedonia, Turkey, UK, Norway, Switzerland, Canada, Japan, and US: EU Commission→

February 19, 2021

Europe

UK asks for public input on tax and regulatory changes needed to improve its investment funds regime: HM Treasury→

February 16, 2021

Digital Economy

UK exploring options for new tax on online sales: Sky News→

February 10, 2021

Americas

In call to UK Chancellor of the Exchequer Sunak, US Treasury secretary Yellen discussed the need to find multilateral solutions to “efficiently and equitably” tax multinational firm income: US Department of Treasury→

January 27, 2021

Americas

US says Austria, Spain, UK digital taxes discriminate, warns on EU tax, three others

January 15, 2021

Digital services taxes enacted in Austria, Spain, and the UK discriminate against US companies within the meaning of Section 301 of the US Trade Act of 1974, the Office of the US Trade Representative . . .

Europe

UK opens multiple criminal fraud probes following MNE tax avoidance investigations, HMRC officials confirm

January 12, 2021

The UK’s HM Revenue and Customs has opened “multiple” criminal fraud investigations stemming from investigations . . .

Americas

US says Italy, India, Turkey digital services taxes are discriminatory, suspends France tariff action

January 7, 2021

Digital services taxes enacted in India, Italy, and Turkey discriminate against the United States; however, for now, no trade actions will be taken, the Office of the US Trade Representative . . .

Asia-Pacific

Energy giant Cairn wins Rs 8,000 crore (USD 1.2 billion) arbitration award in dispute with India over taxation of indirect transfer of assets: Dilasha Seth / Business Standard→

December 23, 2020

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Americas

Taxing multinational group excess profit in the US, UK, and Belgium

December 15, 2020

Dr. J. Harold McClure, New York, notes the EU Advocate General’s recent opinion concerning Belgium’s excess profits tax and discusses approaches to the taxation of these profits in the US, UK, and Belgium . . .

Europe

UK seeks feedback on proposed VAT changes that reflect digital platform “sharing economy”

December 14, 2020

The UK’s HM Treasury has requested public feedback on whether the VAT rules should be changed . . .

Europe

Blackrock’s transfer pricing battle with the UK: unexplored intercompany financing issues

December 11, 2020

Dr. J. Harold McClure, a New York City economist, discusses intercompany loan pricing issues revealed in a November 3 UK Tribunal decision favoring the UK affiliate of investment management group, Blackrock . . .

Europe

Netflix to declare £1bn more UK tax revenue after think tank Tax Watch alleges avoidance: Mark Sweney / The Guardian→

November 30, 2020

Americas

Blackrock prevails in UK transfer pricing dispute

November 18, 2020

Liz Hughes and Anthony Crewe, of Grant Thornton UK LLP, discuss a November 3 UK First-tier Tribunal decision in a transfer pricing dispute involving US-headquartered Blackrock investment management group . . .

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

November 18, 2020

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

Europe

UK report evaluating research and development credit concludes that while the tax credit cost £2.4bn in 2017-18, it may have stimulated £5.8–£6.5bn of additional corporate spending: Georgia Scott & Tim Glinert / HM Revenue & Customs→

November 17, 2020

Europe

UK report evaluating patent box finds a 10 percent increase in investment by companies that using the tax incentive versus those that do not: Max Rowe-Brown & Huw James /HM Revenue & Customs→

November 17, 2020

Europe

UK draft tax proposals include hybrid mismatch fixes, R&D tax credit cap

November 12, 2020

The UK government today proposed additional tax legislation for Finance Bill 2021 . . .

Europe

UK affiliate of Airbnb UK hit with £1.8 million (USD 2.3 million) tax bill for 2019 after audit: Reuters→

September 30, 2020

Europe

UK Autumn 2020 Budget canceled: London Evening Standard→

September 23, 2020

Digital Economy

UK regulations on overdue or overpaid digital services taxes published: Legislation.gov.uk→

September 18, 2020

Europe

UK asks for feedback by November 20 on proposed changes to rules on VAT groups: HM Treasury→

September 14, 2020

Europe

To cover coronavirus spending, UK considers increasing corporate tax rate from 19% to 24%, capital gains tax hike, reducing pension contribution incentives: Reuters→

September 8, 2020

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Europe

UK publishes 2019 report on likely profile of intermediaries affected by DAC6 disclosure, impact on cross-border arrangements: HM Revenue and Customs→

August 27, 2020

Digital Economy

UK denies report it’ll end digital tax to get a trade deal with the US: Silvia Amaro / CNBC→

August 25, 2020

Europe

UK HMRC updates Corporate Finance Manual to address impact of interest restriction on group or consortium loss relief: GOV.UK→

August 20, 2020

Asia-Pacific

Georgia publishes amended text of tax treaties with Iceland, Ireland, Finland, Luxembourg, Slovenia

August 10, 2020

Gela Barshovi a tax adviser and managing partner of TPsolution, Tbilisi, discusses the Republic of Georgia’s July 23 publication of the synthesized text of tax treaties with five countries, as amended by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting . . .

Asia-Pacific

UK guidance updated to state that France, Italy, Malaysia, Turkey taxes are similar to UK’s digital services tax for purposes of cross-border relief: HM Revenue and Customs→

August 5, 2020

Europe

UK asks for public feedback on benefits and risks of introducing tax on online sales of products or services: HM Treasury→

July 31, 2020

Europe

UK says Big Four must separate auditing and consulting practices by 2024 but can share the same parent company: Financial Reporting Council→

July 7, 2020

Americas

OECD to stick to digital tax negotiation timetable despite US opposition

June 18, 2020

The OECD today confirmed that it will continue its work developing a multilateral approach to the taxation of the digital economy before . . .

Americas

US to investigate digital services taxes in India, Brazil, Turkey, Indonesia, the European Union, five EU countries

June 2, 2020

The Office of the US Trade Representative (USTR) today announced that it has initiated an investigation into digital services taxes proposed or adopted in . . .

Europe

EU publishes notice to stakeholders outlining how UK’s EU withdrawal affects VAT for goods after December 31: European Commission→

April 22, 2020

Digital Economy

UK publishes digital services tax guidance

April 7, 2020

The UK on March 18 and 19 published draft chapters for a manual on its . . .

Europe

UK Budget 2020: an overview of the tax proposals

March 11, 2020

Nimesh Shah, a Partner at Blick Rothenberg, London, provides an overview of the tax changes introduced in the UK budget, released today . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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