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International tax reform: public consultation on Pillar One The OECD’s public consultation on the blueprints for international tax reform took place on 14 and 15 January and recordings are available to watch on OECD Web TV. This post looks at the consultation responses on Pillar One which seeks to...
UK tax after IP completion day Although the UK left the EU at 11pm on 31 January 2020, most people would not have noticed any change because the effect of the transitional arrangements under the UK-EU Withdrawal Agreement deferred many of the legal effects of Brexit in UK law. The UK...
Reflections on the EU-UK Co-operation Agreement The EU-UK Trade and Co-operation Agreement (the TCA), which came into provisional effect at 11pm on 31 December, is welcome in terms both of what has been achieved, and in providing a more cordial basis for future EU-UK relations and co-operation.
Reflections on the EU-UK Co-operation Agreement The EU-UK Trade and Co-operation Agreement (the TCA), which came into provisional effect at 11pm on 31 December, is welcome in terms both of what has been achieved, and in providing a more cordial basis for future EU-UK relations and co-operation.
Financial Institution Notices: time to press pause or reset? As mentioned in my earlier post, the UK’s proposed “Financial Institution Notices” (FINs) would give HMRC easier and quicker access to taxpayer data. Under the current rules (in Schedule 36 Finance Act 2008), tribunal approval is needed...
OECD's guidance on transfer pricing implications of COVID-19: nothing “new” in the “new normal”
DAC6: over (in the UK) before it’s begun? The UK has effectively repealed DAC6 for the majority of cases. With effect from 11 pm (UK time) on 31 December 2021 – the day before DAC6 reporting was due to begin in earnest - the UK implementing regulations have been amended to disapply DAC6 in...
More questions than answers in the Gallaher appeals The Upper Tribunal has decided in the Gallaher case that a number of questions should be referred to the CJEU to prior to the end of the transition period on 31 December 2020, although Judge Beare in the First-tier Tribunal (FTT) had decided such a...
The International Comparative Legal Guide - Corporate Tax 2021: Expert analysis chapter William Watson contributes the Expert analysis chapter, "Fiscal State aid: the Commission rebuffed" to The International Comparative Legal Guide - Corporate Tax 2021
The International Comparative Legal Guide - Corporate Tax 2021: UK chapter William Watson and Zoe Andrews contribute the UK chapter to The International Comparative Legal Guide - Corporate Tax 2021
VAT and the sharing economy Yesterday HMRC published a call for evidence on VAT and the sharing economy. It is another piece in the puzzle of whether and how tax rules should be adapted to reflect the change in ways of doing business and the growth of the digital economy.  This...
EU-UK double tax treaty dispute resolution after 2020 With effect from the end of the Brexit transition period, the UK will revoke the Double Taxation Dispute Resolution (EU) Regulations 2020 which had come into effect on 14 February 2020.
Northern Ireland Protocol: agreement in principle The co-chairs of the EU-UK Joint Committee stated that, following their meeting on 8 December 2020, agreement in principle had been reached on the outstanding issues in relation to the implementation of the Withdrawal Agreement and the Northern Ireland...
Taxing multinationals: what the statistics reveal The net yield from the UK’s diverted profits tax (DPT) since it was introduced in April 2015, is £386m according to the latest statistics published by HMRC, way in excess of the £270m-£360m it was forecast to bring in up to and...
Tax and the City Review for November 2020 Mike Lane and Zoe Andrews consider, inter alia, the decisions in Blackrock and Total; and the UK’s approach to the export of financial services to the EU after the end of the Brexit transition period.