Finance Bill 2023-24 Briefings: corporate taxes
Clause 1: Permanent full expensing, etc.
International Tax
International Tax
Reform of transfer pricing, permanent establishments and diverted profits tax
The government said in April 2023 that it would consult on updating the UK’s legislation on transfer pricing, permanent ...
Amount B of Pillar One: OECD consultation
The OECD published a consultation on Amount B of Pillar One in July 2023.
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OECD continues its work in developing the two-pillar solution
In December 2022, the OECD published a number of consultation documents in relation to the two-pillar solution to reform...
New gig economy reporting rules
© Getty images/iStockphoto Very broadly, the Organisation for Economic Co-operation and Development’s (OECD) model repo...
Office of Tax Simplification: Review of hybrid and distance working
The ATT, CIOT and LITRG have responded to the Office of Tax Simplification’s (OTS) review looking for evidence of the em...
Double tax treaties: review of treaty policy positions
In July 2022, HMRC’s Tax Treaty Team sought input in relation to the changes to Article 5 of the OECD Model Tax Conventi...
The two-pillar solution to international tax: where we are now?
In October 2021, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) reached an agreement on a two-pillar sol...
The Global Anti-Base Erosion Model Rules (Pillar 2): CIOT responses
In October 2021, the OECD/G20 Inclusive Framework on BEPS reached an agreement on a two-pillar solution to reform the in...
Corporate re‑domiciliation: CIOT response to government consultation
CIOT responds to government consultation on a new corporate re-domiciliation regime, suggesting that such a regime would...