HMRC are to publish an update to last month’s ‘tax treaties anti-avoidance’ consultation in the light of concerns raised by business and tax advisers.
The proposals would affect a number of entirely bona fide commercial arrangements, argues Philip Baker QC. Kevin Cummings considers whether the proposals amount to an unecessary own goal. HMRC also give their response (below)
‘The world has changed for tax evaders,’ Dave Hartnett, Permanent Secretary for Tax at HMRC, said as HM Treasury announced yesterday’s agreement with Switzerland to address evasion by UK taxpayers.
The UK’s tax deal with Switzerland is expected to come into force in 2013, following scrutiny by Parliament and after ratification procedures in Switzerland are complete, HM Treasury said.
An ‘historic’ agreement with Switzerland will resolve abuse of Swiss banking secrecy by UK taxpayers and is expected to secure billions of pounds of unpaid tax from 2013, HM Treasury announced last night.
A protocol to the UK/Qatar double taxation agreement entered into force on 27 July. The text of the protocol is set out in the schedule to The Double Taxation Relief (Qatar) Order, SI 2011/1684.
Interest payable to overseas investors in UK debt securities is subject to UK withholding tax. Ben Jones and Deepesh Upadhyay examine the four commonly used mitigating routes
The objective of holding multinationals to account in relation to tax planning strategies – one of six stated ‘possible objectives’ – was discounted by a group of tax experts and practitioners reporting to the OECD in April on the case for greater disclosure of tax information.
Bradley Phillips provides a one page overview of the CFC proposals set out in the 110 page consultation document
Jeanette Zaman examines the structure of the new regime and the proposed general purpose exemption, which is intended to replace the current motive test