EU Commission consultation on the re-launch of the Common Consolidated Corporate Tax Base (CCCTB) ‚ CIOT response
‚ On behalf of the Chartered Institute of Taxation (CIOT) we write in response to the technical note and call for evidence published on 4 November 2015. This response is concerned solely with the withdrawal of the practice in BIM66301 under which the remuneration of sub-postmasters can in practice be treated as a trade receipt where a retail trade is carried on from the same premises as the sub-post office, including where the retail trade is carried on by a company.
We understand that Post Office Limited (POL) is rolling out new contracts to sub-postmasters (SPM) under which the SPM is self-employed and agrees to provide services to POL. As a consequence the practice in BIM66301 will then become obsolete.
In our view the practice in BIM66301 should not be withdrawn until after all the new ‚ self-employed‚ contracts have been signed by SPMs. We believe that it would be correct, and would mitigate the compliance costs involved if the proposed approach was changed, to retain the existing treatment until the end of the last tax, or financial, year in which remuneration received under the existing POL ‚ employment‚ contract will be subject to income or corporation tax."