United Kingdom–MNE Tax

Americas

UK to consider US opposition to its planned digital services tax as it negotiates US trade deal: Reuters→

March 2, 2020

Digital Economy

UK Labor MP Dame Margaret Hodge accuses Nexflix of tax avoidance: BBC News→

February 5, 2020

Digital Economy

UK will introduce DST from April 2020 despite OECD plea for delay, Treasury official says: Anna Menin / CityAM→

January 27, 2020

Africa

Shell publishes country-by-country tax report

December 22, 2019

Oil giant Royal Dutch Shell on December 17 published its country-by-country report data for 2018 on the internet, providing . . .

Belgium

Latest EU effort to make country-by-country reporting public fails

December 3, 2019

Davide Anghileri of the University of Lausanne, Switzerland discusses a recent EU Council vote on a proposal to make public country-by-country reports on large multinationals . . .

Europe

UK Labour Party pledges to tax MNEs as unitary firms

November 27, 2019

The UK Labour Party in its manifesto for the upcoming election has committed to . . .

Europe

Netherlands, UK liable for overseas territories’ unpaid customs duties, EU court concludes: The Daily Herald Newspaper St. Maarten→

November 6, 2019

Europe

UK Labour Party may champion formulary apportionment, MP says: The Labour Party→

October 30, 2019

Europe

UK tax authority scrutiny of Airbnb intracompany transactions may lead to litigation, company says: James Graham / BBC News→

October 30, 2019

Europe

Jim Harra permanently appointed HMRC secretary and chief executive: Beckie Smith / Civil Service World→

October 29, 2019

Americas

Unanimity not required to update global rules for taxing multinational groups, OECD’s Saint-Amans says

October 18, 2019

The OECD’s “pillar one” proposal to update the global rules for allocating multinational group profit and related taxing rights can be implemented even if . . .

Europe

Jim Harra appointed interim chief of UK tax agency: Beckie Smith / Civil Service World→

October 2, 2019

Europe

Netherlands hits British American Tobacco with £902m (USD 1.1b) tax bill over fees paid for loans from UK holding company: DutchNews.nl→

September 24, 2019

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Europe

UK raises four pleas before CJEU in appeal of Commission’s state aid decision on CFC rules: KPMG United Kingdom→

September 3, 2019

Americas

Discussion of France and UK digital tax expected to dominate G7 finance ministers meeting: France 24→

July 17, 2019

Americas

UK must scrap DST for US to negotiate trade deal, US officials warn: Ben Riley-Smith / The Telegraph→

August 6, 2019

Europe

UK and Gibraltar commence tax treaty negotiations: Vox→

July 17, 2019

Americas

OECD releases “stage 2” reports on tax dispute resolution in US, UK, Belgium, Switzerland, Canada, Netherlands

August 14, 2019

The OECD on August 13 published six “stage 2” peer review reports assessing whether the United States, United Kingdom, . . .

Europe

UK investigating taxes paid by Candy Crush owner, Activision Blizzard, over royalties paid to Malta and Bermuda: Jon Ungoed-Thomas & Lucy Bacon / The Times→

August 5, 2019

Americas

US lawmakers say UK digital tax would hinder post-Brexit trade deal: Colin Wilhelm & Isabel Gottlieb / Bloomberg Tax→

July 17, 2019

Europe

UK proposes new regulations on hybrid capital instruments

July 9, 2019

UK HM Revenue & Customs on July 5 launched a technical consultation on draft regulations that . . .

Europe

Draft UK rules would require taxpayers and advisors to report cross-border arrangements

July 25, 2019

The UK government on July 22 released . . .

Digital Economy

First look: UK Finance Bill draft legislation includes details on new digital services tax

July 11, 2019

Draft legislation and supporting documents for UK Finance Bill 2019–2020, the vehicle . . .

Europe

UK tribunal reverses controversial decision on Jersey companies’ tax residency under central management and control test

June 13, 2019

David Hughes and Helena Kanczula of Blick Rothenberg Limited, London, discuss an important UK tribunal decision addressing the central management and control test for tax residency . . .

Europe

UK opens consultation on insurance premium tax avoidance, fee manipulation: Matt Sheehan / Reinsurance News→

June 6, 2019

BVI, Bermuda, Cayman top tax haven list; UAE, UK, France most aggressive in lowering other countries withholding tax via treaty: Tax Justice Network→

May 29, 2019

Europe

UK Finance Bill 2019-20: what international businesses need to know

July 17, 2019

David Hughes and Helena Kanczula of Blick Rothenberg Limited, London, discuss selected provisions in draft legislation and explanatory notes to the UK Finance Bill 2019-20 published on July 11 including the UK’s proposed digital services tax . . .

Asia-Pacific

G7 finance ministers agree on some features of international tax rewrite

July 18, 2019

G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. According to the ministers, the international tax and transfer pricing rules . . .

Asia-Pacific

BEPS multilateral tax treaty to enter into force for Ukraine

August 8, 2019

Ukraine today deposited with the OECD legal documents ratifying . . .

Europe

UK launches court challenge to EU Commission’s finding that CFC financing company exemption is state aid: KPMG→

June 24, 2019

Europe

14 MNEs, including Vodafone and GSK, launch court challenge to EU Commission finding of State aid in UK CFC exception: ICAEW Economia→

July 18, 2019

Belgium

Denmark must adopt EU controlled foreign company tax rules, Commission says

July 30, 2019

The EU Commission on July 25 decided to send a reasoned opinion to Denmark for its failure . . .

Europe

EU Commission publishes decision finding UK group financing exemption to CFC tax rule is State aid

July 17, 2019

The European Commission has* published the nonconfidential version of its decision concluding that . . .

Europe

Americas

UK says US-based MNEs underpaid GPB 4.6 billion (USD 5.9 billion) of UK tax last year: Out-law.com→

April 24, 2019

Europe

UK guidance addresses effect of “no-deal” Brexit on VAT system

September 24, 2018

UK HM Reveue and Customs (HMRC) has issued a guidance note that discusses the VAT implications . . .

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin

United Kingdom

UK to consider US opposition to its planned digital services tax as it negotiates US trade deal: Reuters→

UK Labor MP Dame Margaret Hodge accuses Nexflix of tax avoidance: BBC News→

UK will introduce DST from April 2020 despite OECD plea for delay, Treasury official says: Anna Menin / CityAM→

Shell publishes country-by-country tax report

Latest EU effort to make country-by-country reporting public fails

UK Labour Party pledges to tax MNEs as unitary firms

Netherlands, UK liable for overseas territories’ unpaid customs duties, EU court concludes: The Daily Herald Newspaper St. Maarten→

UK Labour Party may champion formulary apportionment, MP says: The Labour Party→

UK tax authority scrutiny of Airbnb intracompany transactions may lead to litigation, company says: James Graham / BBC News→

Jim Harra permanently appointed HMRC secretary and chief executive: Beckie Smith / Civil Service World→

Unanimity not required to update global rules for taxing multinational groups, OECD’s Saint-Amans says

Jim Harra appointed interim chief of UK tax agency: Beckie Smith / Civil Service World→

Netherlands hits British American Tobacco with £902m (USD 1.1b) tax bill over fees paid for loans from UK holding company: DutchNews.nl→

France joins ICAP pilot to jointly assess MNE tax positions

UK raises four pleas before CJEU in appeal of Commission’s state aid decision on CFC rules: KPMG United Kingdom→

Discussion of France and UK digital tax expected to dominate G7 finance ministers meeting: France 24→

UK must scrap DST for US to negotiate trade deal, US officials warn: Ben Riley-Smith / The Telegraph→

UK and Gibraltar commence tax treaty negotiations: Vox→

OECD releases “stage 2” reports on tax dispute resolution in US, UK, Belgium, Switzerland, Canada, Netherlands

UK investigating taxes paid by Candy Crush owner, Activision Blizzard, over royalties paid to Malta and Bermuda: Jon Ungoed-Thomas & Lucy Bacon / The Times→

US lawmakers say UK digital tax would hinder post-Brexit trade deal: Colin Wilhelm & Isabel Gottlieb / Bloomberg Tax→

UK proposes new regulations on hybrid capital instruments

Draft UK rules would require taxpayers and advisors to report cross-border arrangements

First look: UK Finance Bill draft legislation includes details on new digital services tax

UK tribunal reverses controversial decision on Jersey companies’ tax residency under central management and control test

UK opens consultation on insurance premium tax avoidance, fee manipulation: Matt Sheehan / Reinsurance News→

BVI, Bermuda, Cayman top tax haven list; UAE, UK, France most aggressive in lowering other countries withholding tax via treaty: Tax Justice Network→

UK Finance Bill 2019-20: what international businesses need to know

G7 finance ministers agree on some features of international tax rewrite

BEPS multilateral tax treaty to enter into force for Ukraine

UK launches court challenge to EU Commission’s finding that CFC financing company exemption is state aid: KPMG→

14 MNEs, including Vodafone and GSK, launch court challenge to EU Commission finding of State aid in UK CFC exception: ICAEW Economia→

Denmark must adopt EU controlled foreign company tax rules, Commission says

EU Commission publishes decision finding UK group financing exemption to CFC tax rule is State aid

Proposed changes to Ireland’s transfer pricing regime could affect UK interest-free lending structures: KPMG→

UK digital services tax would apply to about 30 entities, HM Treasury officials say: KPMG→

Danny Beeton joins Arendt & Medernach’s transfer pricing practice

UK says US-based MNEs underpaid GPB 4.6 billion (USD 5.9 billion) of UK tax last year: Out-law.com→

UK guidance addresses effect of “no-deal” Brexit on VAT system