United Kingdom
EU proposal to halt multinational tax avoidance through third-country hybrid mismatches stalls
EU finance ministers, during an ECOFIN meeting of the Council of the EU held December 6, were unable to reach agreement on new hybrid mismatch rules designed to prevent multinationals from avoiding tax by exploiting differences between the tax systems of EU and non-EU countries. The ministers disagreed with a Dutch proposal to extend the effective date of the rules and a UK proposal. . .
UK proposes fines for lawyers, accountants, others assisting tax avoidance
The UK today launched a consultation proposing to fine accountants, tax planners, advisers, and others who enable tax avoidance. New rules were also proposed that would make it more likely that existing taxpayer . . .
New UK rules expanding withholding tax on royalties paid to non-residents apply as of 28 June
Sandy Bhogal and Kitty Swanson of Mayer Brown, London, discuss a new law that extends the scope of the UK withholding tax on royalties to payments for the use of trademarks, trade names, and other assets . . .
UK Autumn Statement 2016: leaves little changed
UK tax professional Tim Law discusses Autumn Statement 2016, released today, focusing on tax changes for large business. . .
Protocol to UK / Isle of Man tax treaty enters into force
A protocol amending the double tax treaty between the Isle of Man and the UK entered into force March 23 the . . .
UK proposes tax on royalties paid to low tax countries, hitting multinational digital businesses
UK Chancellor Philip Hammond in his Autumn Budget speech today proposed a new tax on multinational firms designed to primarily reach firms in the digital sector. The UK government also published a position paper outlining its thinking on the taxation of digital firms. Following consultation, the UK government . . .
UK consults on proposal to limit tax deductibility of corporate interest expense
As a part of its effort to address aggressive tax planning by large multinational groups, the UK government on May 12 launched a consultation on a proposal to introduce rules restricting interest . . .
Taiwan offers VAT refund to some foreign enterprises without fixed place of business
Taiwan’s taxation office announced Monday that foreign enterprises and other entities from specified countries that have no fixed place of business in Taiwan but engage in. . .
UK draft tax legislation would modify carried-forward loss rules, limit interest deductions
Julian Feiner of Dentons, London, discusses draft UK proposals, released yesterday, that would change the taxation of carried-forward losses and interest deductions . . .
UK’s HMRC details new requirement for large businesses to publish tax strategy
The UK’s HM Revenue and Customs (HMRC) on March 31 published draft guidance describing new rules that will require large companies, partnerships . . .
UK wins court case challenging Bank of Ireland tax scheme involving intragroup transfer of interest rate swaps
A Bank of Ireland subsidiary, Bristol & West (B&W), located in the UK, has lost its appeal in UK courts in a tax avoidance case that involved its novation of a portfolio of “in the money” interest-rate swaps . . .
EU finance ministers split on public release of multinational corporation tax data
Dutch finance minister and president of the Eurogroup, Jeroen Dijsselbloem, expressed support for a proposal that would mandate public release of country-by-country tax data on multinationals, while finance ministers from Malta, Belgium, and Austria . . .
UK finalizes country-by-country reporting rules for multinationals
The UK on February 26 issued final rules requiring large UK-parented multinationals and some UK subsidiaries of large multinationals to file annual country-by-country reports to HM Revenue and Customs (HMRC). The regulations finalize draft regulations on the topic . . .
31 nations sign agreement on exchange of country-by-country transfer pricing reports
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .
UK requires companies in Caymans, BVI, other territories, to publicly disclose ownership
Britain’s overseas territories, including the tax havens of Cayman Islands, British Virgin Islands, and Bermuda, must introduce publicly accessible registers of the beneficial ownership of companies located in their jurisdictions before 2021 or the UK will require them to do so, a law approved by UK Parliament . . .
UK releases draft legislation to limit interest deductions of large corporations
The UK government, on December 5, published draft clauses for a tax law that will limit the interest deductions of large corporations, to be included in the 2017 . . .