The debate is moving on from theory to nuts and bolts delivery. Chris Sanger and Jack Gifford (EY) examine the UK’s consultation that does little to promote tax simplification.
Following the OECD’s October 2021 statement updating the July conceptual agreement on the ‘two-pillar solution to address the tax challenges arising from the digitalisation of the economy’ the road seemed paved for the swift publication of the pillar two model rules and a model treaty provision giving effect to the subject to tax rule (STTR) by the end of November 2021. However a number of delays resulted in only the pillar two model rules being published on 20 December 2021 with the associated commentary and the STTR model treaty provision still yet to be published.
Despite delays HM Treasury and HMRC have wasted no time in publishing an open consultation on the UK implementation...
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The debate is moving on from theory to nuts and bolts delivery. Chris Sanger and Jack Gifford (EY) examine the UK’s consultation that does little to promote tax simplification.
Following the OECD’s October 2021 statement updating the July conceptual agreement on the ‘two-pillar solution to address the tax challenges arising from the digitalisation of the economy’ the road seemed paved for the swift publication of the pillar two model rules and a model treaty provision giving effect to the subject to tax rule (STTR) by the end of November 2021. However a number of delays resulted in only the pillar two model rules being published on 20 December 2021 with the associated commentary and the STTR model treaty provision still yet to be published.
Despite delays HM Treasury and HMRC have wasted no time in publishing an open consultation on the UK implementation...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
