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OECD road map for the digital economy

20 July 2019

Business with a global presence should review the proposals made by the OECD to see how they could be affected.

Could tax reform save the high street?

24 May 2019

It has been hard to miss the strains that UK high street retailers have been facing. Many have called for a change in the way the retail sector is taxed, to reflect the way today’s consumers shop. The latest, and perhaps most high-profile voice calling for reform, is Tesco’s chief executive Dave Lewis. So what are the available tax policy options and how would they work?

Is the end in sight for LIBOR?

24 April 2019

The Financial Conduct Authority (FCA) announced in 2017 that the London inter-bank offered rate (LIBOR) would be phased out by the end of 2021. Declining volumes of the inter-bank lending transactions that underpin LIBOR resulted in what the FCA perceived as an increased reliance on the interpretation of non-lending data when calculating LIBOR.

Intangibles reform – small steps in the right direction

16 February 2019

The Government consulted on the reform of the corporate intangibles tax regime in Spring 2018, with the aim of simplifying it and making it more competitive. We are now starting to see the outcome of that process and this article considers two of the key developments to date.

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New disclosure facility to tackle the diversion of profits away from the UK

16 February 2019

HMRC believes some multi-national enterprises have cross border arrangements in place which are not consistent with the OECD’s transfer pricing guidelines, that result in the diversion of profits away from the UK such that profits are taxed at lower rates or not at all. These types of arrangements are targeted by transfer pricing rules, together with the diverted profits tax (DPT) legislation, effective from 1 April 2015.

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New allowances for structures and buildings and proposed new capital loss utilisation rules

19 January 2019

The recent Budget introduced some significant proposals in relation to the treatment of structures and buildings for tax purposes , with the introduction of a new capital allowances regime – the structures and buildings allowance.

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New disclosure facility opened by HMRC to tackle the diversion of profits away from the UK
Andrew Hinsley

11 January 2019

HMRC believes some multi-national enterprises have cross border arrangements in place which are not consistent with the Organisation for Economic Co-operation and Development’s (OECD) transfer pricing guidelines, that result in the diversion of profits away from the UK such that profits are taxed at lower rates or not at all. These types of arrangements are targeted by the diverted profits tax (DPT) legislation, effective from 1 April 2015.

Digital services tax – Is it worth the gamble?

03 December 2018

The new digital services tax (DST) will add compliance duties on the taxpayer, and there is a substantial risk that it will introduce more complexity to the UK tax regime. Discover how businesses may face uncertainty as they struggle to define if their activities fall within the scope of DST.

Withholding taxes on interest and royalties post-Brexit

19 October 2018

The tax treatment of intra-group interest and royalties payments between UK and EU companies may be impacted by the UK leaving the EU.

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Is there a future for HMRC transfer pricing agreements?

14 September 2018

HMRC recently published its transfer pricing and diverted profits tax (DPT) statistics for 2017/18. The statistics may provide insight into changes in taxpayer behaviour in the area of transfer pricing.

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