In the first of a new series, Allan Cinnamon provides a global review of tax treaty developments, including the UK’s DPT.
This new series of articles will track tax treaty developments worldwide explaining their potential impact on UK companies doing international business and foreign companies inbound to the UK. The material will be based on bilateral treaty developments court decisions and domestic changes as well as progress on the treaty related aspects of the BEPS action plans.
This first article looks back at developments over the last few months. Future articles will examine new developments as they occur.
On 10 December 2014 HMRC published a consultation draft of the proposed legislation on the DPT. Non-resident companies (excluding small and medium-sized)...
