DOUBLE TAX RELIEF

John Watson, former head of tax at Ashurst, with assistance of Martin Precious, reviews the options for reform of the international taxation of corporate profits, in view of the OECD's action plan on tackling base erosion and profit shifting.

The following draft Orders in Council have been laid before the House of Commons for approval:

Some immediate reaction on the OECD's Action Plan on Base Erosion and Profit Shifting.

HMRC has announced that the  (DTTP) scheme has been revised from April 2013. The scheme operates for overseas corporate lenders in a country with which the UK has a double taxation treaty that includes an interest or income from a debt-claims...

James Bullock looks at the activist group's failed attempt to challenge HMRC

A first time comprehensive double taxation agreement between the UK and Albania was signed on 26 March, HMRC announced. It ‘generally’ follows the OECD model convention.

New comprehensive double taxation conventions with Norway and Spain were signed on 14 March.

SI 2011/2725

A protocol amending the UK’s double taxation agreement with the People’s Republic of China (SI 2011/2724) was signed on 27 February.

Paul Radcliffe and Mark Semple consider whether the OECD’s latest proposals on ‘beneficial ownership’ represent the end of the debate on this issue or just another step towards the end.