The Diverted Profits Tax (DPT) has been a significant area of focus for taxpayers and tax authorities in the UK and Australia. The tax targets specific situations in which taxable profits are alleged to have been “diverted”...more
HMRC has published a consultation paper anticipating reforms to the UK’s rules on transfer pricing, permanent establishments and diverted profits tax. This is a wide-ranging review and it may be that its constituent parts...more
Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more
On 3 March 2021, UK’s Chancellor Rishi Sunak announced the 2021 Budget, outlining the state of the economy and the government’s fiscal plans for the near to medium term. As expected, the chancellor’s speech focused on changes...more
The UK tax authority (HMRC) has announced a new Profits Diversion Compliance Facility (PDCF), as part of its efforts to ensure that multinationals do not use artificial arrangements to divert profit to lower tax...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
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2018 on 29 October 2018. The Budget was delivered against the backdrop of the UK’s negotiations with the European Union concerning Brexit. ...more
UK Tax News and Developments - The OTS publishes its report "Value added tax: routes to simplification" - On 7 November, the Office of Tax Simplification (OTS) published its first report on VAT, which included a range...more
1. Introduction - This client alert provides a summary of key UK tax considerations when a nonresident invests into UK commercial real estate. There are a number of holding structures for investment into UK real estate...more
The UK government has proposed its "diverted profits tax" in order "to counteract contrived arrangements used by large groups (typically multinational enterprises) that result in the erosion of the UK tax base." There follows...more