Non-resident CGT: UK Property Rich Collective Investment Vehicles – draft regulations
Finance Act 2019 introduced new provisions further extending the taxation of gains accruing to non-UK residents on UK pr...
International Tax
International Tax
Digital services tax: draft Finance Bill
It was announced at Budget 2018 that the UK would implement a DST, and the government subsequently consulted on the prop...
Offshore receipts in respect of intangible property: draft regulations and guidance
The CIOT has commented on the draft regulations (and explanatory note) which will make amendments to the rules taxing Of...
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Tax and the digitalised economy
In the Budget 2018, the government announced that it would introduce a UK digital services tax (DST) from April 2020; a ...
The Inheritance Tax Account forms (IHT100) Project
The collection of Inheritance Tax Account (IHT100) forms, together with various supplementary pages, are used to tell HM...
Avoidance involving profit fragmentation: Clause 16
Clause 16 and Schedule 4 of the Finance Bill introduces new anti-avoidance rules from April 2019 to tackle profit splitt...
Offshore receipts in respect of intangible property: Clause 15
In Budget 2018 the Chancellor announced a revised proposal to tax income from intangible property held in low-tax jurisd...
Transfer pricing: BEPS Actions 8–10 Financial Transactions
In July 2018 the OECD published a non-consensus discussion draft on transfer pricing for financial transactions under th...
Tax avoidance involving profit fragmentation
HMRC launched a consultation titled Tax avoidance involving profit fragmentation on 10 April 2018.
Digitalised economy: recent consultations and developments
On 13 March 2018, the UK government published an updated position paper setting out its views on Corporate tax and the d...