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In Europe

United Kingdom: HMRC look to expand transfer pricing documentation requirements – increased compliance burden on the horizon?

by and 6 Mins Read

Since 2015, the UK has adopted the minimum standard of required transfer pricing documentation articulated in BEPS Action 13 (“Guidance on Transfer Pricing Documentation and Country-by-Country Reporting”), namely Country-by-Country-Reporting (CbCR). In its latest consultation paper, HMRC have set out their intention to move away from the BEPS Action 13 minimum standard and to require taxpayers of large multinational enterprise groups (MNE groups) to prepare a master file and local files together with supplemental evidence logs. 

HMRC have also set out a proposal for all UK taxpayers that fall under UK transfer pricing rules to submit an international dealings schedule (IDS) – a highly structured form to capture specific intragroup transactions and activities. If introduced, this would be a significant step change from current documentation requirements and one that will likely increase the compliance burden for many.

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In Europe

United Kingdom: Uncertain tax treatments v2.0

by , and 13 Mins Read

The inaugural ‘Tax Day’ on 23 March saw a range of announcements on the future of UK tax compliance. One of most significant measures is the re-launch of the proposal to require Large Businesses to notify HMRC of uncertain tax treatments that they have adopted.

This second consultation addresses the criticisms expressed when the proposal was first put forward during 2020. The original trigger of HMRC “may not agree with/is likely to challenge” the treatment adopted by a taxpayer has been replaced with eight separate triggers designed to apply the reporting requirement on a more objective basis.

The revised proposal looks a step in the right direction, but there remain a number of practical concerns to be ironed out. We would recommend that Large Business taxpayers continue to engage with the proposal to ensure it is implemented on proportionate and practicable terms.

The intention is for the requirement to apply to returns that are due to be filed from 1 April 2022 onwards. Therefore, for annual taxes such as corporation tax, this is a live issue that affects the current financial period for the vast majority of taxpayers.

In Covid-19

United Kingdom: Progress of UK product safety – Soon to be fir for the 21st century?

by , , and 5 Mins Read

In brief The UK government has set out its plans to explore changes to the UK’s product safety and product liability laws (Review). The Review, which has been commenced by the Office for Product Safety and Standards (OPSS, the UK government’s product safety body which was established in 2018) and…

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In Corporate Compliance

United Kingdom: Human Rights Act Review: Signalling a rollback of regulation and judicial oversight post Brexit?

by 7 Mins Read

Corporates interested in the degree of regulatory oversight likely to operate in the UK post Brexit will be watching the ongoing review of the Human Rights Act 1998 (HRA) with interest. It may signal a dilution of the protections to individual rights contained in the HRA, including the commitments to observe rights in legislation and operation of public functions, as well as the ability to challenge failures to do so via the courts.

In Employment

United Kingdom: New legislation proposed to extend protection from health and safety detriment to workers

by , and 1 Min Read

In R (Independent Workers’ Union of Great Britain) v The Secretary of State for Work and Pensions, the High Court upheld a claim brought by the IWGB union that the UK had failed to properly implement Articles 8(4) and (5) of the EU Health and Safety Framework Directive (89/391/EC) by limiting protection from detriment on health and safety grounds under section 44 of the Employment Rights Act (ERA) to employees. A copy of our update on that case can be found here

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