International Taxes

 


The Chartered Institute of Taxation (CIOT) sent a letter to HMRC in response to a call for comments on Double Taxation Treaties 2019/20. 

The Chartered Institute of Taxation (CIOT) responds to the Organisation for Economic Co-operation and Development (OECD) consultation on Global Anti-Base Erosion Proposal (‘GloBE’) – Pillar Two.

There was not much love for the government’s Digital Services Tax (DST) at the latest CIOT/Institute for Fiscal Studies (IFS) debate.

The Labour Party have published their general election manifesto, which includes plans for higher corporation tax, income tax increases for those earning more than £80,000 and taxing capital gains and dividends at income tax rates with a single allowance.

The Chartered Institute of Taxation (CIOT) responds to the OECD public consultation on the Secretariat Proposal for a ‘Unified Approach’ under Pillar One, which is progressing the conversation around the impact of digitalisation of the economy and is continuing the work towards a consensus-based, long term solution which address the tax challenges raised. 

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 On 11 July the government also published draft guidance and a summary of the feedback to the consultation and the government’s response (summary of responses).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.