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Hybrid legislation - latest developments

24 January 2020

UK hybrid mismatch rules have been in place since 1 January 2017. While highly complex, they aim to neutralise the effect of tax mismatch arrangements most commonly seen in cross-border scenarios.

Digital services tax - a bargaining chip?

24 January 2020

Will the digital services tax still be brought into legislation, as proposed, in April 2020, particularly in light of the intended trade deal the UK is yet to start negotiating with the United States?

Update on HMRC’s profit diversion compliance facility

16 November 2019

HMRC launched the profit diversion compliance facility in January 2019 to tackle the perceived continued diversion of profits away from the UK.

HMRC’s new business risk review

19 October 2019

HMRC has over recent months been piloting a new approach to the way it evaluates the tax risk profile of large businesses. The new business risk review encompasses a number of changes to assess risk and these changes will apply from 1 October 2019.

DAC6 – the EU directive on early disclosure of cross-border transactions

19 October 2019

HMRC has published a consultation paper and draft secondary legislation on the implementation of the EU mandatory disclosure rules as set out in Directive 2018/822, known as DAC6, requiring intermediaries, service providers and relevant tax-payers to notify HMRC of defined cross border transactions with effect from 1 July 2020.

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.

Corporate tax instalment payments changes

14 June 2019

The Government has introduced an accelerated quarterly instalment payment regime, for accounting periods commencing on or after 1 April 2019, for ‘very large companies’. The new regime requires very large companies (companies with taxable profits exceeding £20m) to pay their corporation tax instalments earlier, with the first payment typically due two and a half months after the start of the accounting period and the final payment due in the final month of the period.

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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