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The US's reaction to France's DST
In her recent post, Zoe Andrews suggested that, given the importance for the UK of securing a post-Brexit trade agreement with the US, now might not be the best time for the UK to introduce a digital services tax. Support for her view is to be found in ...
Fixed establishment through parent-subsidiary relationship
In Case C-547/18, Dong Yang Electronics, the ECJ has been asked to revisit the definition of fixed establishment (FE) for VAT purposes and to clarify whether a subsidiary can be considered an FE of its parent. How the ECJ has ruled to date A separate ent...
What does independent taxation mean?
The Labour Party has been in trouble this week due to its promise to scrap the UK tax marriage allowance. This allowance was introduced in 2015 and enables a non-working spouse or civil partner to transfer £1,250 of their tax personal allowance to their h...
Easier access for EU CIUs, AIFs and pension funds to Spanish tax exemption
New rules will significantly ease the access by qualified Collective Investment Undertakings (CIUs), Alternative Investment Undertakings (AIFs) and pension funds incorporated, or formed, in a European Union (EU) Member State to a specific domestic exempti...
Is now a good time for a UK digital services tax?
The message was clear at last week's OECD public consultation on the reform of the international tax rules that there is a need to fix the rules to avoid the chaos of a multitude of unilateral digital service tax (DST) measures. The UK is one of the many ...
Is now a good time for a UK digital services tax?
The message was clear at last week's OECD public consultation on the reform of the international tax rules that there is a need to fix the rules to avoid the chaos of a multitude of unilateral digital service tax (DST) measures. The UK is one of the many ...
Labour's Fair Tax Programme: the £6.2bn question...
...or "Seeing as everyone else is now giving 'fact-checking a go'". When Labour published its 2019 Election manifesto last week it was accompanied by a document entitled "Funding Real Change" which set out where Labour intended to get the extra £82.9bn a ...
Building legal foundations: UKJT publishes legal statement on the status of cryptoassets and smart contracts
The UK Jurisdiction Taskforce (or ‘UKJT’) has published a legal statement on the status of cryptoassets and the enforceability of smart contracts under English private law, areas which have generated considerable debate in recent years. From this foundati...
Is it time to reconsider policy on bank taxation?
As discussed in my Viewpoint video, the UK government is heavily reliant on taxes paid by financial services. The finance and insurance sector was the largest single contributor to corporation tax in 2017/18 accounting for 26% of corporation tax liabiliti...
GloBE: learning the lessons of the past
The OECD published its Pillar Two paper on the Global Anti-Base Erosion (GloBE) Proposal on Friday (Zoe Andrews' earlier post provides an overview) which requested comments on the "use of financial accounts as a starting point for the tax base determinati...