The Chartered Institute of Taxation (CIOT) has welcomed proposed reforms to the UK legislation on transfer pricing, permanent establishments, and diverted profits tax.Continue Reading
UK
Transfer pricing news, BEPS news, and international tax news in United Kingdom
Russia rejects UK request to lift tax treaty suspension
Russian Finance Ministry has rejected UK’s request to withdraw the partial suspension of the Russia-UK tax treaty.Continue Reading
Revoke suspension of tax treaty: UK tells Russia
The UK government has asked Russia to revoke the suspension of the 1994 UK-Russia tax treaty.Continue Reading
UK tax leaders bracing for global minimum tax impact
A majority of UK tax leaders expect their tax planning and business operations to experience moderate to significant change once the global minimum tax is implemented, according to a EY Tax and Finance Operations Survey.Continue Reading
Bermuda to levy corporate tax on MNEs from 2025
Bermuda is consulting stakeholders on a new corporate tax regime from 2025 in view of the OECD’s proposed global minimum tax rules.Continue Reading
Vladimir Putin suspends tax treaties with ‘unfriendly’ countries
Russian President Vladimir Putin has suspended several tax treaties with “unfriendly” countries.
The suspension decree was signed on August 8. The decree includes tax treaties signed with the US, the UK, and Canada, and other countries that had imposed unilateral economic sanctions on Russia.
“In view of the need to take urgent measures in connection with the unfriendly actions of a number of foreign states against the Russian Federation, its citizens and legal entities, the President resolved to suspend a number of provisions of tax treaties with the United States of America, European Union countries and other unfriendly states,” an official statement from the President’s office notes.
The suspension was proposed by the Finance Ministry in March 2023.
UK tightens grip on promoters of tax avoidance schemes
UK tax authority has published draft tax law aimed at imposing tougher legal consequences on promoters of tax avoidance schemes.Continue Reading
Alvarez & Marsal Tax bolsters UK transfer pricing practice
Global professional services firm Alvarez & Marsal (A&M) has appointed Imran Khan to bolster the firm’s UK transfer pricing practice.Continue Reading
Gibraltar to implement global minimum tax from 2025
Gibraltar is seeking to implement a new tax regime for companies within the scope of OECD’s proposed Pillar Two tax rules, and a domestic minimum top-up tax, Chief Minister Fabian Picardo said while delivering the draft Budget for 2023-24.Continue Reading
UK publishes draft law implementing undertaxed profits rule
UK government has published draft legislation to implement the undertaxed profits rule under its domestic law.Continue Reading
A&M Tax appoints transfer pricing expert Rasmus Steiness as Senior Director
Alvarez & Marsal Tax LLP has appointed transfer pricing expert Rasmus Steiness as a Senior Director.
Steiness will work with Managing Director Richard Syratt in London to help international clients solve increasingly complex transfer pricing issues.
Steiness brings more than 16 years of experience supporting banking, capital market, and fintech clients. He specializes in the alignment of tax and operating models, IP, and financial transactions.
Transfer Pricing Reform in Brazil and ‘Options Realistically Available’: New Tax Disputes Ahead?
Law No. 14596/2023 introduced new transfer pricing rules in the Brazilian tax system, in line with the arm’s length standard. The transfer pricing reform is a result of a long project carried out by the Brazilian Federal Revenue Office since 2018, with support from the Organization for Economic Cooperation and Development (OECD) and the United Kingdom (UK), aiming at convergence of Brazil’s transfer pricing rules and the OECD Transfer Pricing Guidelines.Continue Reading
So you dislike the OECD global minimum corporate tax? Tough. The UK now has to implement it, or we’ll lose out.
The reason for this is simple:
There are 137 countries coloured on that map. Each has signed up to the OECD global minimum tax (sometimes referred to as GLoBE or “Pillar Two”).
Some are already implementing – including such free market stalwarts as Singapore. Others are discussing implementation details. And many others have signed but are yet to kick off implementation – international tax measures are always slow, and there have been distractions. There is an interactive version of our OECD globe here.1
This means GLoBE is likely to have a critical mass of implementing countries. Its design renders that very important.Continue Reading
UK publishes draft technical guidance on Pillar Two rules
UK government has published partial draft technical guidance setting out additional information on administration, chargeability, and scope for multinational top-up tax and domestic top-up tax legislation.Continue Reading
UK modernizing transfer pricing, diverted profits tax rules
UK government is seeking stakeholders’ views on potential reforms to the UK international tax legislation on transfer pricing, permanent establishment, and Diverted Profits Tax.Continue Reading
Des Hanna joins Andersen UK as international tax director
Des Hanna has joined leading tax firm Andersen as a director in the firm’s international tax group.Continue Reading
UK consulting on draft transfer pricing records regulations
The UK tax authority is consulting on the draft Transfer Pricing Records Regulations, 2023.Continue Reading
UK gets £358m in digital services tax in 2021
UK government has raised more revenue than expected in digital services tax and has increased the amount of UK tax paid by big digital companies, according to a report by the National Audit Office.Continue Reading
UK shares public input on mandatory tax disclosure rules
The UK government has received 20 written responses from tax and law firms on the proposed mandatory disclosure rules (MDR). Continue Reading
UK updates tax provision to reflect latest OECD transfer pricing guidance
The update comes into effect for accounting periods beginning on or after January 1, 2023, for corporation tax purposes.Continue Reading
UK releases draft rules on global minimum tax
UK government, on July 20, released draft rules aimed at ensuring multinational enterprises (MNEs) operating within the UK pay a global minimum level of tax.
The draft rules are in line with the agreement on a 2 Pillar solution to reform the international tax framework made by the G20 — Organisation for Economic Co-operation and Development Inclusive Framework on Base Erosion and Profit Shifting (BEPS) last year.Continue Reading
International tax reform takes center stage in G7 meeting
The G7 (which includes the UK, the US, Canada, Japan, Germany, France, Italy, plus the EU) agreed the principles of an ambitious two Pillar global solution to tackle the tax challenges arising from an increasingly globalized and digital global economy.Continue Reading
US suspends digital services tax retaliatory tariffs
On June 2, 2020, USTR initiated investigations into digital services tax adopted or under consideration in ten jurisdictions: Austria, Brazil, the Czech Republic, the European Union, India, Indonesia, Italy, Spain, Turkey, and the UK.Continue Reading
Global minimum corporate tax rate should be 15 percent: US Treasury
The US Treasury expressed its belief that the international tax architecture must be stabilized, that the global playing field must be fair, and that we must create an environment in which countries work together to maintain our tax bases and ensure the global tax system is equitable.Continue Reading
US, Europe discuss digital economy taxation
Janet Yellen, who took oath as the 78th Secretary of the US Department of the Treasury on January 26, held a discussion with counterparts in France, Germany and the UK on digital economy taxation.Continue Reading
Digital services taxes of Austria, Spain and UK discriminatory: United States
In a release issued on January 14, the USTR said that the each one of these digital services taxes discriminates against US companies, is inconsistent with prevailing principles of international taxation, and burden or restricts US commerce.Continue Reading
UK to repeal DAC6 in 2021
The UK tax authority, HM Revenue and Customs, has announced that it will repeal the DAC6 reporting requirement in 2021 and replace it with the OECD’s mandatory disclosure rules (MDR).
The announcement was made after completion of the negotiations between the UK and the EU on a Free Trade Agreement (FTA).
In a letter sent to stakeholders on December 31, HMRC said that reporting under DAC6 will still be required for a limited time, but only for arrangements which meet hallmarks under Category D, in line with the UK’s obligations under the FTA.
Category D sets out specific hallmarks concerning automatic exchange of information and beneficial ownership.
The International Tax Enforcement (Disclosable Arrangements) (Amendment) (No. 2) (EU Exit) Regulations, 2020 – laid before the House of Commons on December 30 – state that “(5) For the purposes of these Regulations, the DAC is to be read as if— (h) in Annex IV, Part 1 [the Main Benefit Test] and hallmark categories A, B, C and E in Part II were omitted.”
In the coming year, the UK will consult on and implement the OECD’s MDR as soon as practicable, to replace DAC6 and transition from European to international rules, HMRC told stakeholders.
UK defers DAC6 deadlines by six months
The deferral is aimed at providing taxpayers and intermediaries dealing with the impacts of the Covid-19 pandemic with additional time to ensure that they can comply with their obligations.Continue Reading
Unilateral action on digital economy taxation would heighten trade tensions: OECD
Gurría was responding to recent statements and exchanges regarding the ongoing negotiations to address the tax challenges of the digitalisation of the economy.Continue Reading
US Trade Representative to investigate digital services tax rules in EU, nine others
These ten trading partners are: Austria, Brazil, the Czech Republic, the European Union, India, Indonesia, Italy, Spain, Turkey, and the United Kingdom.Continue Reading
Financial associations call upon EU Commission to defer DAC6 reporting
UK 2020 Budget retains 19% corporate tax rate
The Government is introducing from April 1, 2020, a new two percent digital services tax on the revenues earned by certain digital businesses.Continue Reading
Will Smith joins White & Case as tax partner
Global law firm White & Case LLP has hired Will Smith as a partner in the firm’s London office.
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Travers Smith appoints Emily Clark as Head of Tax
Emily Clark has joined corporate law firm Travers Smith LLP as head of tax.
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BDO LLP, London hires new international tax partner
Julia McCullagh has joined BDO LLP’s London office as Partner, International Corporate Tax.Continue Reading
BVI to accept country by country report filings from March 2020
International Tax Authority informs BVI Constituent Entities, that are part of Multinational Entity Group, that it will soon be ready to receive filings for CbC reporting.Continue Reading
Diverted profits tax yields UK over GBP 5 billion in extra tax
Between 2019-2020, HMRC secured GBP 480 million through DPT investigations.Continue Reading
Amazon underlines guiding principles on digital economy taxation
Any proposed tax must be levied on profits and not revenue, Amazon’s Vice President (Global Tax), Kurt Lamp, said.Continue Reading
Don’t focus only on corporation tax: Amazon
Amazon is a major UK employer and currently employs over 27,500 UK people. The company said that this number would increase to over 29,500 this year.
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New EU corporate tax avoidance rules enter into force
The new anti-abuse measures entered into force on January 1, 2019.Continue Reading
Indian tax authority undergoing ratification process for BEPS MLI
Important process of ratifying the BEPS MLI is on. In 2019-2020, the provisions will come into effect, says Akhilesh Ranjan.
Continue ReadingFrance, Germany propose new digital tax plan
France and Germany urged the EU Council to adopt the proposed digital services tax by March 2019.Continue Reading
Qatar signs BEPS Multilateral Instrument to tackle tax avoidance
Qatar is the 85th jurisdiction to sign the BEPS Convention, which now covers nearly 1,500 bilateral tax treaties.Continue Reading
Ireland, Malta Close ‘Single Malt’ Tax Avoidance Structure
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable at editor@transferpricingnews.com
Ireland and Malta have agreed to close the “Single Malt” – an aggressive tax planning structure in which some multinational corporations use a company incorporated in Ireland but tax-resident in Malta.
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BDO Melbourne Gets New Tax Partner in Michael Smith
Michael Smith has joined BDO Melbourne’s transfer pricing team as a partner.
Smith has nearly 20 years’ of transfer pricing experience from around the world. He has worked in London, New York, and Sydney. Continue Reading
Ireland Consulting on Corporate Anti-Tax Avoidance Measures
On November 14, 2018, Ireland’s Department of Finance published for public comments a consultation document on the hybrid mismatch and interest limitation measures to be introduced as part of the implementation of the EU Anti-Tax Avoidance Directives (ATAD and ATAD2).
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UK Launches Consultation on Digital Services Tax
The UK Government is seeking stakeholders’ views on the detailed design, implementation, and administration of the proposed two percent digital services tax (DST).Continue Reading
UK Announces 2% Digital Services Tax From 2020
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
UK would introduce a two percent digital services tax (DST) to ensure digital businesses pay tax that reflects the value they derive from UK users, UK Chancellor Philip Hammond announced in his October 29 Budget Speech.Continue Reading
Ireland Signs Order to Ratify BEPS Convention
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
Ireland’s Government has signed an Order to facilitate ratification of the OECD’s Multilateral Instrument to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS).Continue Reading
Mutual Agreement Procedure Statistics Published for 2017
The OECD on October 10 published its 2017 mutual agreement procedure (MAP) statistics covering 85 tax jurisdictions.
According to the 2017 MAP statistics, new transfer pricing MAP cases are up by 25 percent and other MAP cases by 50 percent. Anecdotal evidence suggests that the increase in new MAP cases is due to a range of factors including the effects of the new reporting framework and increased awareness of and expectations from taxpayers about MAP, the OECD noted.Continue Reading
Two New Tax Directors Join RSM’s Manchester Office
Leading audit, tax, and consulting firm RSM has appointed two new tax directors to join the firm’s Manchester office.Continue Reading
More Countries Ratify BEPS Convention
Australia, France, Japan, and the Slovak Republic have deposited their instruments of ratification of the OECD’s Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS).
For these four countries, the BEPS Convention would enter into force from January 1, 2019. The Convention entered into force last month for New Zealand, Serbia, Sweden, and the UK.Continue Reading
EU Commission to Drop Infringement Proceedings in Ireland-Apple State Aid Decision
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
The EU Commission is now to withdraw infringement proceedings against Ireland as the Government has now completed full recovery of the alleged State aid from Apple.Continue Reading
Ireland to Expand Transfer Pricing Rules by 2020, Introduce CFC Law
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
Ireland’s Finance Minister Paschal Donohoe has published the country’s Corporation Tax Roadmap outlining the steps that the Government will take in the area of international tax law over the next few years.Continue Reading
MAP Peer Review Reports Out for Australia, Ireland, Japan, Five Others
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
The OECD on August 30 published stage 1 mutual agreement procedure (MAP) peer review reports of the following eight jurisdictions: Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, and Portugal.Continue Reading
Quantera Global, Africa Transfer Pricing Now Allies
Transfer pricing advisory firm Quantera Global has announced its strategic partnership with Africa Transfer Pricing, a professional services firm specializing in transfer pricing in South Africa.Continue Reading
Swiss, UK Tax Treaty to Include BEPS Minimum Standards
The Swiss Federal Council on August 22 adopted the dispatch concerning a protocol of amendment to the Swiss-UK tax treaty for the attention of Parliament.Continue Reading
Guernsey to Introduce Substance Requirements in Tax Law
Guernsey’s Government is consulting businesses on a law that would require companies tax-resident in Guernsey to demonstrate they have sufficient substance in the island.Continue Reading
UK Raises £388 million from Diverted Profits Tax Law in 2017-18
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
The UK tax authority, HM Revenue and Customs (HMRC), raised GBP388m from the diverted profits tax (DPT) legislation in 2017-18, according to the Transfer Pricing and Diverted Profits Tax Statistics published on July 31.Continue Reading
DLA Piper Appoints Vicki Bales as Transfer Pricing Director
Global law firm DLA Piper has announced the appointment of Vicki Bales as a Transfer Pricing director in the firm’s international tax practice. Bales will be based in London.Continue Reading
New Mexican Transfer Pricing Adjustment Regulations Explained
By Guillermo Villaseñor-Tadeo (Partner, Sánchez Devanny, Mexico) and Pedro Palma-Cruz (Attorney, Sánchez Devanny, Mexico)
Mexico’s Tax Administration Service on July 11, 2018, updated the country’s existing regulations concerning transfer pricing adjustments as set out in rules 3.9.1.1 to 3.9.1.5 of the Resolución Miscelánea Fiscal. The changes are aimed at clarifying many questions that arose from the enactment of the first set of regulations on transfer pricing adjustments last year. In broad terms, the regulations can be classified as: definition and types, application, requirements, and timing issues and deadlines. These are discussed below.Continue Reading
Former Head of Tax of Jardine Motors Joins RSM
Audit, tax, and consulting firm RSM has appointed Robert De La Rue, former Head of Tax of Jardine Motors Group, as a tax partner in Chelmsford.Continue Reading
Baker McKenzie Elects New Tax Partners
Law firm Baker McKenzie has announced the election of 13 new tax partners.
The newly elected partners are: Michael Nixon (Singapore), Simone Bridges (Sydney), Kirill Vikulov (Moscow), David Jamieson (London), Jessica Eden (London), Rodrigo Castillo Cottin (Bogota), Paul F. DePasquale (New York), Tatyana Johnson (New York), Victor Alejandro Morales-Chavez (Mexico City), Jonathan Welbel (Chicago), Joshua Nixt (New York), Andrew C. O’Brien-Penney (Chicago), and Ivan Tsios (Chicago).Continue Reading
UK Finalizes BEPS Convention Reservations
The UK Government has published a final list of its reservations and notifications under the Multilateral Convention to implement tax treaty-related base erosion and profit shifting (BEPS) measures.Continue Reading
UK to Amend Corporate Interest Restriction Rules
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
The UK Government has published draft legislation that would make technical amendments to the country’s corporate interest restriction rules to ensure the corporation tax regime works as intended.Continue Reading
Guernsey Signs New Tax Treaty With UK
Guernsey has signed a new tax treaty with the UK. The new tax treaty replaces the one that has been in force since 1951.
The new tax treaty is based, broadly, on the OECD Model Tax Convention, which Guernsey has generally followed in its negotiations with other jurisdictions in recent years. The text of the tax treaty incorporates some of the recent international standards designed to prevent base erosion and profit shifting (BEPS). Continue Reading
UK, Isle of Man Sign New Tax Treaty
The governments of UK and Isle of Man signed a new tax treaty on July 2.
The tax treaty is based on the latest OECD Model Tax Convention and includes provisions to reflect the OECD’s base erosion and profit shifting (BEPS) measures.Continue Reading
UK Updates Definition of ‘Transfer Pricing Guidelines’
The UK Government has published an Order, which would update the definition of “transfer pricing guidelines” in the UK legislation.Continue Reading
Sarah Churton Joins KPMG UK’s International Tax Team
KPMG UK has announced the appointment of Sarah Churton to its international tax practice.Continue Reading
UK Publishes Tax Guidance on MAP Framework
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
On February 20, 2018, the UK Government published “Statement of Practice 1 (2018)” on the country’s mutual agreement procedure (MAP) framework. The Statement supersedes “Statement of Practice 1 (2011).”Continue Reading
Cayman Islands Issues Advisory on CbC Reporting Requirement
By Alex Cooper
On February 2, 2018, the Cayman Islands’ Ministry of Financial Services issued an Industry Advisory on the Islands’ country-by-country (CbC) reporting notification requirements.Continue Reading
Hogan Lovells Expands Transfer Pricing Team with New Hire
International law firm Hogan Lovells has hired Tom McFarlane as head of transfer pricing (EMEA) for the firm’s growing transfer pricing practice. He will be working from the firm’s London office.Continue Reading
UK, US, Six Others Launch Multilateral Tax Risk Assurance Program For MNEs
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
Eight tax administrations, including the UK and the US, have launched a pilot program for the multilateral risk assessment of multinational corporations.Continue Reading
UK ‘Brought In’ Over GBP8bn from Large Companies in 2016-17
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
Mel Stride, Financial Secretary to the UK Treasury, has said that the Government has brought in and protected more than GBP8bn in 2016-17 from UK’s largest companies.Continue Reading
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