International Taxes


As expected as part of the ‘Tax Day’ announcements, HMRC has published the second consultation on notification of uncertain tax treatment by large businesses, as well as a summary of responses to the first consultation.

MPs begin debating the Finance Bill in committee today. Committee of the Whole House will take place on Monday 19 and Tuesday 20 April, with public bill committee commencing on Thursday 22 April.

This page bring together briefing notes and representations from the CIOT, our Low Incomes Tax Reform Group and our sister body, the Association of Taxation Technicians, produced for committee stage of Finance Bill 2021, which begins on Monday 19 April. 

On Tax Day the government published a consultation on Transfer pricing documentation

At Budget 2020, the government announced that it would carry out a review of the UK funds regime, covering tax and relevant areas of regulation. The review started with a consultation on the tax treatment of asset-holding companies in alternative fund structures, to which the government responded in December 2020, and also published a consultation (the second consultation) into some particular aspects relevant to asset-holding companies.

The UK and EU agreed a Trade and Cooperation Agreement (TCA) on Christmas Eve. This was passed by the UK Parliament on 30 December and took effect at the end of the following day as the UK left the single market and customs union at the end of the Brexit transition period (also known as the implementation period). While the agreeing of a deal (even a fairly limited one) has been widely welcomed, the rushed process, requiring businesses to adopt new ways of working at a few days notice, has faced criticism.

With EU directive DAC 6 ceasing to apply in the UK at 11pm tonight HMRC have informed us that reporting under DAC 6 will still be required for a limited time, but only for arrangements which meet hallmarks under category D, in line with the UK’s obligations under the Free Trade Agreement with the EU.

Legislation to establish the special VAT and customs regime that will apply in Northern Ireland from next month has completed its passage through the UK Parliament ahead of the end of the Brexit Transition Period.

The Chartered Institute of Taxation (CIOT) have written to the HMRC Tax Treaty Team regarding a review of Double Taxation Treaties 2020/21.