UK: HMRC publishes guidance on transfer pricing records for PEs
The United Kingdom (UK) HRMC has issued guidance on the transfer pricing records requirements for permanent establishments (PEs) in accordance with the amendments made by Finance (No. 2) Act 2023. The Local files and Master files requirements for
See MoreUnited Kingdom: HMRC updates APA guidance
The HMRC has recently updated its guidance (INTM 422000 et seq) on Advance Pricing Agreements (APAs). The updated guidance provides more comprehensive information, particularly in terms of the formal process and HMRC's expected timeframes. These
See MoreUK updates transfer pricing documentation requirements
The United Kingdom (UK) has published the Transfer Pricing Records Regulations 2023, which updated transfer pricing documentation requirements by introducing Local file and Master file requirements. The UK has officially updated its transfer
See MoreUK: Statistics on Creative Industries Tax Relief
On 24 August 2023 HMRC published updated statistics for creative industries tax relief, showing that GBP 1.66 billion was paid out in tax relief for creative industries in 2021/22. The increase was due mainly to a significant rise in the amount of
See MoreUK: HMRC announces new reporting regulations for digital platform operators (DAC7)
On 20 July 2023, the United Kingdom’s HMRC issued a policy paper outlining a comprehensive plan to establish reporting regulations for digital platform operators operating in the United Kingdom (UK). This initiative, which aligns with the OECD
See MoreUK: Capital Gains Tax Statistics for 2022
The update on statistics for capital gains tax (CGT) released on 3 August 2023 notes that record amounts of capital gains were reported in 2021/22 and record amounts of CGT were collected. The statistics are based on the self-assessment tax returns
See MoreUnited Kingdom Enacts Finance Bill 2023
On 11 July 2023, the United Kingdom (UK) Finance (No.2) Act 2023 was enacted, that incorporates provisions to adopt the Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Pillar Two income inclusion
See MoreUK: Review of Noncompliance in Research and Development Tax Relief Schemes
On 17 July 2023 HMRC published an analysis of the scale of non-compliance in the research and development (R&D) tax relief schemes and the approach taken to enforcing taxpayer compliance. The UK has two R&D tax relief schemes, a scheme
See MoreUK amends CbC notification Requirement
On 5 July 2023, the House of Commons in the United Kingdom (UK) made a significant decision by accepting Statutory Instrument No. 752/2023 to amend tax regulations on BEPS country-by-country (CbC) notification requirement. The UK government has
See MoreUK: Tax Gap for 2021/22
On 22 June 2023 HMRC published details of the UK’s tax gap for 2021/22. The tax gap is a measure of the difference between the amount of tax that should have been collected by HMRC, and the amount that was actually paid. The tax that should be
See MoreUK: HMRC Explains Delays on MTD for Income Tax
On 20 June 2023 the head of HMRC noted in a hearing before the Public Accounts Committee (PAC) in parliament that the complexity of Making Tax Digital (MTD) had been underestimated. As a result, there had been continual delays to MTD for income
See MoreUK: Consultation on Changes to Transfer Pricing Rules
On 19 June 2023 the UK government launched a consultation on potential reforms to the UK legislation on transfer pricing, permanent establishments, and diverted profits tax. Transfer Pricing - provision Currently section 147 TIOPA refers to a
See MoreUK: HMRC publishes draft guidance on global minimum tax rules
On 15 June 2023, the HMRC has published partial draft guidance on multinational top-up tax and domestic top-up tax, following their introduction in the Spring 2023 Finance Bill. Multinational top-up tax is a new tax on multinational enterprise
See MoreUK: Second Reading of Spring Finance Bill 2023
On 13 June 2023 the UK government published the Tax Information and Impact Notes for government amendments at the report stage of the Spring Finance Bill 2023. The Bill includes the following measures: Multinational Top-up tax: UK adoption of
See MoreUK: Consultation on Voluntary Standard for Customs Intermediaries
On 5 June 2023 the UK launched a consultation looking for the views of stakeholders on a proposal to introduce a voluntary standard for customs intermediaries. Views are invited from interested parties by 30 August 2023. The consultation follows
See MoreIMF Report Assesses the UK Economy
On 23 May 2023 the IMF issued a report following consultations with the UK under Article IV of the IMF’s articles of agreement. The report notes that the UK economy is projected to maintain positive growth in 2023, avoiding a recession owing to
See MoreUK: Statistics for Investments under the Enterprise Investment Scheme
On 17 May 2023 the UK government published statistics for the Enterprise Investment Scheme (EIS), the Seed Enterprise Investment Scheme (SEIS) and Social Investment Tax Relief (SITR). These latest statistics show the amount of funds raised by
See MoreUK: Tax Administration – New Legislative Pilots
On 27 April 2023 the UK published a consultation document with the title The Tax Administration Framework Review - Creating Innovative Change through New Legislative Pilots. The document looks at the use of a “sandbox” piloting model
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