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Is the DST compatible with the UK’s international obligations?

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The OECD has warned against unilateral measures leading to taxation of the digitalised economy outside the international tax framework. The UK is one country that has proposed such measures: UK digital services tax. Unlike the normal charge to corporation tax on income, this proposed tax could be levied on entities with no taxable UK presence. The UK government’s stated view is that the tax is consistent with the UK’s international obligations. However, it may well breach both double tax treaties and international trade law. Given the OECD’s warning, affected groups should refresh their engagement with HM Treasury and HMRC, raising these concerns in particular.
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