Born of the OECD’s base erosion and profit shifting (BEPS) project, the Pillar Two rules introduce a global minimum corporate tax rate of 15% on multinationals of a certain size.
The reforms reflect the outcome of an...more
UK Chancellor Jeremy Hunt delivered his first full Spring Budget on Wednesday 15 March. It is interesting (that is, interesting in a rather specific tax context) that, despite the fiscal volatility of 2022, this was in fact...more
2023 is set to be a year of change for the global tax landscape. After many years of negotiation, development and consultation, implementation of the OECD’s Pillar One and Pillar Two reforms to international taxation is now...more
The UK government has used the opportunity of its Autumn Statement 2022, delivered on 17 November, to confirm that the Finance Bill 2022 will include legislation introducing a 15% global minimum corporation tax rate, to have...more
On 20 December 2021, the OECD published keenly awaited model rules designed to implement Pillar Two of its ambitious plans to reform international taxation. ...more
To date, 132 jurisdictions have committed to the OECD’s two-pillar plan to reform international tax rules, as set out in its statement of 1 July 2021. Although the genesis of the proposed reforms relates to the taxation of...more
The UK government is pressing ahead with its proposal to require large businesses to notify their “uncertain tax positions” to HMRC.
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On 21 June 2016, the EU Council reached agreement on the EU Anti Tax Avoidance Directive (“ATAD”). The ATAD is expected to be adopted in a forthcoming ECOFIN meeting, possibly on 12 July 2016.
The Council had reached...more
On 1 January 2016, a new exemption from UK withholding tax for interest paid on “qualifying private placements” came into force.
The conditions to the new exemption focus on various attributes that HMRC consider to be...more
HMRC are expected to consult on revisions to their published guidance to clarify the circumstances in which they will treat loan servicing in securitisation arrangements as exempt for VAT purposes....more
Today’s Autumn Statement saw financial institutions hit by a surprise proposal to limit the proportion of their profits which can be reduced by the carry forward of past losses, which will mean tax is paid on those profits...more
The UK was challenging the legality of the decision taken by the Council of the European Union to authorise the enhanced cooperation procedure (ECP) to establish an FTT for a subgroup of willing Member States. The UK, and a...more