International Taxes

 


The Chartered Institute of Taxation (CIOT) responds to the consultation document which sets out HMRC’s current thinking and approach to interpreting DAC6.

Liberal Democrat conference in Bournemouth backed radical changes to corporation tax, including restrictions to reliefs, a boost to capital allowances and extending the tax to cover highly profitable partnerships and other unincorporated businesses. For multinationals the party wants a wider definition of permanent establishment and, longer term, a global system of business taxation. In an autumn election a penny on income tax for health and social care, and restoring the 20% rate of corporation tax to increase funding of public services, would likely be key policies.

We refer to the draft legislation published on 11 July 2019 intended to be included in the next Finance Bill to give effect to the UK’s Digital Services Tax (DST). That the UK would implement a DST was announced at Budget 2018, and the government subsequently consulted on the proposed DST. On 11 July the government also published draft guidance and a summary of the feedback to the consultation and the government’s response (summary of responses). We set out our comments on the proposed approach and the draft legislation and guidance.

The CIOT comments on the draft legislation published on 11 July 2019 (L-day) intended to be included in the next Finance Bill to give effect to the Corporate Capital Loss Restriction (CCLR). The CCLR was announced at Budget 2018 and the government subsequently consulted on the detail of the delivery of the CCLR. 

Over the last decade, we have witnessed a revolution in cross-border tax information exchange and reporting—with significant repercussions for global tax compliance, tax planning and tax enforcement.

The CIOT comments on the Double Taxation Dispute Resolution (EU) Regulations. 

The Chartered Institute of Taxation (CIOT) is delighted to announce that the number of international tax professionals who have achieved ADIT (Advanced Diploma in International Taxation) certification has grown to more than 1,000, after the latest exams took place in June 2019.

The CIOT response to the draft regulations on Offshore Receipts in respect of Intangible Property.

This technical consultation seeks views on draft Regulations for the implementation of Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms.

The CIOT comments sent to HMT on the Stamp Duty Land Tax: non-UK resident surcharge consultation.