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International tax news update

18 July 2020

Whilst the impact of the coronavirus outbreak remains the main focus for business at this time, international businesses should also consider the effect of some key international tax developments.

Consultation on hybrid and other mismatches

20 June 2020

The tax documents published following the Chancellor’s Budget on 11 March included a consultation on the hybrid and other mismatches rules. We delve into the detail.

Consultation on notification of uncertain tax treatments

19 May 2020

A consultation on uncertain tax treatments was published after this year's Budget. This article provides an outline of a proposed new regime, which could significantly impact the relationship between HMRC and many large businesses.

Coronavirus - international support

19 May 2020

The outbreak of coronavirus and the economic uncertainty brought about as a result, has meant that many governments and tax administrations around the world have swiftly put in place measures to try and stabilise their economies.

Starbucks wins in EC state aid challenge

26 February 2020

Recent years have seen the European Commission (EC) taking on some of the world’s largest businesses in its efforts to eliminate illegal state aid. However, in September 2019, Starbucks won its appeal.

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?

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.

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.