The de minimis mismatch, how to identify the group and relevant companies, clearing intercompany loans ... Robert Langston looks at five key issues that arise in practice concerning the debt cap rules
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)
There is a compelling case for devolving corporation tax to Scotland, the Scottish Finance Secretary said in a discussion paper on options for reform.
‘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.