Europe
United Kingdom
Europe
Europe
Guidance on Northern Ireland’s corporate tax regime published
The UK tax authority on September 26 published draft guidance on the operation of Northern Ireland’s corporation tax regime, setting out . . .
Europe
Europe
Americas
Tax officials crafting plan to jointly identify large multinationals with low risk of tax avoidance
Eight countries are working on a new program to jointly review large multinationals’ tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
Europe
Draft UK tax guidance clarifies hybrid mismatch law
The UK, on December 9, published draft tax guidance to clarify aspects of hybrid mismatch legislation which will take effect January 1, 2017. The legislation, introduced . . .
Asia-Pacific
United Kingdom
Europe
UK details businesses’ use of patent box tax incentive
The UK gave away £342.9 2 million (USD 452.6 million) in tax breaks, mostly to large corporations, through its patent box tax incentive the first year the program was established, data released today by HM Revenue and Customs has . . .
Digital Economy
Europe
Asia-Pacific
Australian diverted profits tax legislation introduced
Julian Feiner of Dentons, London, discusses proposed Australian legislation, introduced into Parliament February 9, that would implement a diverted profits tax, comparing the draft to the UK DPT . . .
Europe
UK Treasury minister defends Google tax settlement
UK Treasury Secretary David Gauke today defended an HM Revenue and Customs settlement with Google relating to back taxes, telling Members of Parliament that the company . . .
Europe
Europe
Denmark
Estonia
Algeria
Asia-Pacific
UAE signs tax treaty with United Kingdom
The United Arab Emirates and the United Kingdom signed a tax treaty . . .
Asia-Pacific
India, UK sign bilateral advance pricing agreements
India and the UK have signed two bilateral advance pricing agreements (APAs) to resolve transfer pricing disputes, the first such agreements between the nations, India’s . . .
Europe
Africa
UK signs tax treaties with Colombia and Lesotho
The UK’s HM Revenue & Customs has announced that the UK has signed tax treaties . . .
Europe
UK considers adding secondary adjustment rule to transfer pricing legislation
The United Kingdom’s HM Revenue and Customs on May 26 opened a consultation on a proposal to add a secondary adjustment mechanism . . .
Europe
Google’s UK tax settlement resolved transfer pricing disputes, no diverted profits tax paid
Google’s recently announced settlement with UK HM Revenue and Customs requires the company to pay additional tax on account of transfer pricing adjustments and does not include any diverted profits tax (DPT) payment, HMRC documents . . .
Europe
EU Competition Commissioner to review UK/Google tax settlement: Rowena Mason & Jennifer Rankin / The Guardian→
Also, UK tax officials and Google reps have been summoned to appear at a Public Accounts Committee hearing February 11 to testify about the settlement. See: The Guardian.
Europe
UK solicits businesses’ views on VAT grouping following ECJ decisions in Larentia + Minerva and Marenave and Skandia
The UK’s HM Revenue & Customs on January 14 advised that it is seeking feedback from business on how to respond to European Court of Justice decisions in Larentia + Minerva and Marenave and Skandia . . .
Europe
UK-Sweden tax treaty enters into force
The UK-Sweden tax treaty, signed March 26, 2015, entered into force on December 20, 2015, HM Revenue and Customs announced January 13. The treaty . . .
Europe
UK tax chief Lin Homer to step down in April
Lin Homer announced Monday that she will leave HM Revenue and Customs (HMRC) in April, after more than four years as Chief Executive and Permanent . . .
Bulgaria
UK tax treaties with Croatia, Bulgaria, Kosovo enter into force
The UK’s HM Revenue & Customs on January 8 announced that tax treaties with Croatia, Bulgaria, and Kosovo have entered into force. The UK’s tax treaty with Croatia entered into . . .
Europe
Transfer pricing specialist Jukka Karjalainen joins Baker & McKenzie’s UK office
Jukka Karjalainen has joined Baker & McKenzie’s UK business transformation practice as a tax leader, the firm announced January 5. Karjalainen, a transfer pricing specialist, will be advising . . .
Europe
UK tax authority publishes draft examples for proposed hybrid mismatch legislation
The UK’s HM Revenue and Customs, on December 22, issued a series of draft examples illustrating the application of hybrid mismatch rules in previously released tax . . .
Europe
Canada
UK and Canada agree to details of arbitration clause in tax treaty, text available
Canada and the UK have signed an agreement specifying the procedures for arbitration of tax disputes between the two nations, Canada’s Department of Finance . . .
Europe
UK diverted profits tax hits MNEs that avoid PE rules, route profits through tax havens
The UK government on December 10 proposed a new 25 percent tax on “diverted profits,” targeting MNEs that engage tax avoidance transactions, including MNEs that “exploit” permanent establishment (PE) rules and that reduce their tax liability through transactions that lack substance. The new tax, first announced in UK Autumn Statement 2014, affects only large MNEs, is . . .
Americas
US signs first competent authority arrangements to implement FATCA IGAs with Australia and UK
The US IRS announced November 24 that it has signed competent authority arrangements (CCAs) with Australia and the UK to establish . . .
Americas
Belgium
EU committee publishes letters from 13 nations on tax ruling practices
A European Parliament committee has published letters from EU member state officials describing tax ruling practices, efforts to combat tax avoidance, and compliance with EU spontaneous exchange of information directives. The letters, published by. . .
Belgium
EU Commission to investigate tax ruling practices of all EU states
The European Commission has enlarged its state aid investigation into private tax ruling practices to cover all 28 European Union states. “The Commission will ask Member States to provide information about their tax ruling practice, in particular to confirm whether they provide tax rulings, and, if they do, to request a list of all companies that have received a tax ruling from 2010 to 2013,” the Commission said December 17 in a press release . . .
