UK: HMRC wins case on employment status
HMRC has won a case concerning employment status and the IR35 rules. The IR35 legislation aims to ensure that in defined circumstances individuals working for an intermediary such as a personal service companies pay the same tax as an employee
See MoreGermany: Capital gains 100% tax-exempt for foreign corporate shareholders
On 25 October 2017, the German Federal Tax Court (decision dated 31 May 2017) ruled in favor of foreign shareholders selling shares in a German corporation. Capital gains realized upon sale of shares in a German resident corporation by non-resident
See MoreCanada: Finance Department announces public consultation on draft tax legislative proposals
The Finance Department released a public consultation on September 8, 2017 regarding draft legislative and regulatory proposals on the Goods and Services Tax/Harmonized Sales Tax (GST/HST) and excise duty as well as income tax. GST/HST and Excise
See MoreUK: HMRC reveals details of employment remuneration tax avoidance schemes
HMRC has published details of tax avoidance schemes that are being used by employers, agencies and other intermediaries to avoid payment of income tax and national insurance contributions. These and other types of tax avoidance scheme are published
See MoreIMF report comments on economic position of Japan
The IMF issued a report on Japan’s economic position on 31 July 2017 following the conclusion of discussions under Article IV of the IMF’s articles of association. The report notes that Japan’s economy is growing above potential with positive
See MoreOECD: Meeting of Inclusive Framework on BEPS
On 22 June 2017 the third meeting of the inclusive framework on base erosion and profit shifting (BEPS) took place in the Netherlands with representatives of 83 countries and jurisdictions and 12 international and regional organizations. The
See MoreUK: Revised professional code of conduct to combat tax avoidance
On 1 November 2016 HMRC announced that seven leading tax and accountancy bodies in the UK have revised their Professional Conduct in Relation to Tax (PCRT) to emphasize that members of these professional bodies should not encourage tax avoidance
See MoreUK: Report highlights HMRC tax investigations of high net worth individuals
The UK’s National Audit Office has noted that the tax authority HMRC is currently pursuing around a third of the UK’s wealthiest people for a total of around GBP 1.9 billion in underpaid tax. The National Audit Office (NAO) is a watchdog that
See MoreOECD: Discussion draft on branch mismatch structures
On 22 August 2016 the OECD released a discussion draft on branch mismatch structures under Action 2 of the OECD report on base erosion and profit shifting (BEPS). Comments are invited from interested parties by 19 September 2016. The discussion
See MoreUK: Consultation on tackling disguised remuneration
On 10 August 2016 HMRC issued a consultation document on tackling disguised remuneration. This consultation follows the issue earlier in the year of an overview of the proposed changes and a technical note setting out the background and intended
See MoreUK: Research report on intermediaries legislation
On 12 July 2016 HMRC published the results of research undertaken to understand the implications for employers and engagers if they are given responsibility for operating the intermediaries legislation. The intermediaries legislation combats tax
See MoreUK: Consultation on reforms to the intermediaries legislation for the public sector
The intermediaries legislation was introduced in the UK to ensure that people doing the same work for the same pay were liable to the same tax and national insurance contributions whether employed directly or working through an intermediary such as
See MoreOECD: Taxing Wages 2016
The OECD has published Taxing Wages 2016 which shows that tax on income from labor remained at 35.9% for OECD countries in 2015, the same as in the previous year. Before that the tax burden on labor had been rising for some years. The publication
See MoreUK: Responses to consultation on company distributions
On 24 March 2016 the UK published a summary of responses to the consultation on company distributions. This consultation followed the announcement by the government in the summer budget of 2015 that the taxation of dividend income would be reformed
See MoreUK: Regulations on Country by Country Reporting
The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016 contain detailed regulation on country by country (CbC) reporting. The regulations provide the detailed procedure for CbC reporting in line with the
See MoreUK: deemed domicile for income tax and capital gains tax
The UK is currently conducting a consultation on measures changing the rules for non-UK domiciled individuals. The changes are to be included in the Finance Bill 2016 and are to take effect from 6 April 2017. Draft legislation has been introduced to
See MoreUK: HMRC Publishes Statistics on Accelerated Payments Notices
The UK tax authority HMRC has noted in a press release of 8 February 2008 that more than GBP 2 million has been collected under the accelerated payments provisions. Under these provisions the users of tax avoidance schemes must pay tax up-front
See MoreIMF Technical Note on introducing a GAAR
On 31 January 2016 the IMF issued a technical note on ensuring that a general anti-avoidance rule (GAAR) achieves its purpose. Many countries have either introduced a GAAR or are considering its introduction, which the objective of combating
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