In applying the UK’s transfer pricing rules, tax advisers have to think beyond the amount of the debt and the interest rate to get comfortable that an intra-group loan is going to be tax deductible. Following a recent case,...more
When applying the UK’s transfer pricing rules to compare an intra-group loan to the hypothetical arm’s length transaction that an independent third-party lender would have agreed to, there is no scope to read in covenants...more
HMRC have announced that it will be holding a webinar on Tuesday 6 October to provide an update on its Profit Diversion Compliance Facility (PDCF). The facility is a mechanism that multinational firms can use to settle...more
What is the Profit Diversion Compliance Facility?
What the PDCF does -
The facility is a mechanism that multinational firms can use to settle potential tax liabilities for past years that remain open. It relates to...more
The German Federal Ministry of Finance has published a draft law for the implementation of the EU Anti-Tax Avoidance Directive (ATAD Implementation Act) on 10 December 2019. This draft includes inter alia a new section 1a...more
Following-up from our previous blogs on Tech Tax, we thought it would be useful to take a whirlwind tour of what to expect in tax and transfer pricing related topics in 2020. But for those that are curious, why are such...more
2/6/2020
/ Anti-Avoidance ,
Digital Services Tax ,
Disclosure ,
Disclosure Requirements ,
EU ,
EU Directive ,
Financial Transactions ,
International Tax Issues ,
OECD ,
Regulatory Requirements ,
State Aid ,
Tax Avoidance ,
Tax Planning ,
Tax Reform ,
Transfer Pricing ,
Transparency
What is it about? OECD proposals to tax the digital economy which will significantly impact all large tech companies that are consumer oriented.
What will the impact be? Businesses will pay more tax. Impact on cash-flow,...more
12/2/2019
/ Base Erosion Tax ,
Corporate Taxes ,
Digital Marketplace ,
FinTech ,
International Tax Issues ,
Multinationals ,
OECD ,
Profits ,
Public Meetings ,
Tax Liability ,
Tax Planning
It’s been a busy month in the world of tax for tech companies. France and the UK are introducing digital services taxes, and serious work is underway at the OECD that may result in a shake-up of the international tax system...more
The dynamism of the Technology, Media and Telecoms sector is set to continue.
Challengers can reach scale seemingly overnight, forcing market change at a similar speed. Established business models are upended, driving...more
6/21/2019
/ 5G Network ,
Antitrust Provisions ,
Artificial Intelligence ,
Big Data ,
Digital Media ,
Drones ,
eSports ,
Foreign Investment ,
General Data Protection Regulation (GDPR) ,
Hulu ,
Intellectual Property Protection ,
Internet Streaming ,
Netflix ,
Outer Space ,
Satellites ,
Standard Essential Patents ,
Telecommunications ,
Television Programming ,
Trade Policy ,
UK Brexit
We recently had the opportunity to hear HMRC's latest views on valuing growth shares for UK tax purposes.
We consider below the importance of share valuation in general and provide an update on HMRC's approach to valuing...more
The UK tax authority, HMRC, recently announced the introduction of a new Profit Diversion Compliance Facility, which is aimed at tackling the avoidance of tax by diverting profits outside the UK without proper economic...more
HMRC has announced today the introduction of a new Profits Diversion Compliance Facility, which is aimed at tackling the avoidance of tax by multinationals by diverting profits outside the UK without proper economic...more
HMRC announced today the introduction of their new Profits Diversion Compliance Facility (PDCF). This is a way for multinationals to take the initiative and explain their legal and operational structures before HMRC launch...more
After much speculation, UK Chancellor Philip Hammond announced today in his annual budget speech that the UK will introduce a Digital Services Tax (DST) with effect from April 2020. ...more
The Chancellor of the Exchequer’s statements of intent on a digital service tax and competition law reforms reinforce other recent indications that the UK government is looking seriously at making significant changes to the...more
On 13 July 2018, Hong Kong enacted detailed transfer pricing legislation through the gazettal of the Inland Revenue (Amendment) (No. 6) Ordinance 2018 ("the Amendment Ordinance")....more