Corporate Taxes

 


Anyone with even a passing interest in tech or tax will be aware of recent hubbub around the proposed introduction of a UK digital services tax (DST).  The new tax, which will be targeted at specific highly digitised profit-making business models that generate over £500m, was announced by the Chancellor, Philip Hammond, at the recent Autumn Budget.

The CIOT FB18-19 representations to the public bill committee.

MPs debated and agreed clauses 1-4 of Finance Bill (No.3), agreeing that the government should continue to levy income tax and corporation tax, and the rates of income tax for 2019-20. Attempts by opposition MPs to get the committee to take oral evidence from experts, and to require the government to review aspects of tax policy, were rejected.

This was a fairly quiet conference on the tax front for the Conservatives, new announcements limited to a stamp duty increase for foreign buyers, edging a little closer to a Digital Services Tax, tweaks to the apprenticeship levy and another year of a fuel duty freeze. Various outriders would like to see more radical changes though – especially corporation tax cuts – and there are hints these might be considered depending on the outcome of the Brexit process.

Chancellor Philip Hammond said in his Conservative Conference speech that Britain will unilaterally implement a digital service tax if there is no international agreement soon on how to tax big internet companies, blaming US tax reforms for slow multilateral progress. Speaking at a CIOT/IFS fringe debate at Conservative conference the next day, titled ‘What does fair business taxation look like in a digital world?’ Tax Minister Mel Stride said to ‘expect some things coming down the line’ from the Treasury on Hammond’s pledge.

The CIOT comments sent to HMRC on Carried forward corporation tax losses: compliance obligations.

The CIOT comments sent to HMRC/HMT on Corporate tax and the digital economy.

The CIOT comments sent to HMRC on FB 2018-19 Clause 6 Schedules 1-2 Disposal of assets by non-UK residents and payments on account.

Following discussions between CIOT and HMRC over the last few months, HMRC have made some changes to their guidance in the Company Taxation Manual on the Targeted Anti-Avoidance Rule (TAAR) contained in s396B ITTOIA 2005.  

The CIOT comments on the EU Commission Recommendation relating to the corporate taxation of a significant digital presence.