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BLOG: International tax reform – now more worth the effort? At a webinar on 18 January, the OECD presented its findings on the impact of international tax reform in advance of the full report which will follow in the coming months.
BLOG: Digital Services Taxes: draft MLC provisions published by the OECD For the second year running, the OECD provided an update on the two-pillared international tax reform project just days before Christmas. On 20 December 2022, it released draft Multilateral Convention (MLC) provisions on digital services taxes and other...
BLOG: Electricity Generator Levy Draft legislation for the Electricity Generator Levy (EGL) was published on 20 December 2022 for inclusion in the Spring Finance Bill. It was published alongside a new “supplementary technical note”, intended to help generators prepare for the EGL. The...
BLOG: Provisional agreement reached on the European Union's Carbon Border Adjustment Mechanism The Council of the European Union issued a press release on Tuesday, stating that negotiators representing the European Parliament and Council had agreed terms on which to implement a Carbon Border Adjustment Mechanism (CBAM). This agreement...
HMRC v BlackRock Holdco 5 LLC: transfer pricing and unallowable purpose Mike Lane on the Upper Tribunal decision in HMRC v BlackRock Holdco 5 LLC on transfer pricing and the loan relationships unallowable purpose rule. First published in the British Tax Review.
BLOG: New double taxation agreement between the UK and Brazil In September 2022, Brazil and the UK announced a first round of negotiations for a double taxation agreement (DTA) following several years of discussions on technical and policy issues. It appears that the formal negotiations progressed well, given that a...
BLOG: A capital mess? The Court of Appeal’s judgment in Centrica Overseas Holdings In what is thankfully an unusual occurrence in legal practice, I was about to press send on an email advising a client on an issue (in this case, the deductibility of expenses incurred in respect of the sale of a subsidiary), very much relying on the...
Tax and the City Review for November 2022 Mike Lane and Zoe Andrews discuss the VAT decisions of the CJEU in O Fundusz (sub-participation agreements) and of the Supreme Court in NHS Lothian (VAT recovery), HMRC’s Guidelines for Compliance, the OECD’s report on tax incentives and the...
BLOG: Further changes to the UK's R&D tax regime Against a background of some “difficult decisions” being taken by Chancellor Jeremy Hunt in his 2022 Autumn Statement on 17 November 2022, the Treasury unveiled some further changes to the UK’s Research and Development (R&D) tax regime, signalling a...
BLOG: Taxing decisions in the Autumn Statement Undoubtedly, the UK’s Autumn Statement delivered by Chancellor Jeremy Hunt on 17 November 2022 reflected some difficult decisions (see the Treasury’s news story and the text of his speech). But at least the one relating to the GloBE rules under Pillar 2...
BLOG: Progress on international tax reform? I may have previously complained about the stream of consultations on different aspects of the OECD's international tax reform project, but now, in the face of the back-and-forth of UK domestic tax policy, I almost find myself taking solace in its steady...
Tax and the City Review for October 2022 In Burlington, the FTT considers, for the first time, the purpose test which often appears in double tax treaties. The UT dismisses HMRC’s appeal in Aozora GMAC confirming that unilateral relief is available for US withholding tax on interest paid...
BLOG: Riding into the sunset: the Retained EU Law (Revocation and Reform) Bill At the end of 2023, certain EU laws and rights retained as part of domestic law in the UK following its departure from the EU will fall away if the Retained EU Law (Revocation and Reform) Bill currently before the UK Parliament is enacted, save where they...
Growth Plan 2022 — Issues for corporates: a maximalist mini-Budget The only thing miniature about Kwasi Kwarteng's mini-Budget on Friday 23 September is the amount left to pay on your tax bill. At least, that's the chancellor's big idea.
BLOG: Some imp-s'more-tant news... VAT has often held the answer to many of life's greatest mysteries. Why does my sandwich cost more if I eat in rather than eat out? Or if I say yes to wanting it heated, even if I do take-it-away? Answer: VAT. A cold sandwich to take away is a standard...