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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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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.

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