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
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