In brief The UK’s fintech sector is due to get a major boost in reforms suggested as part of the Kalifa Review of UK Fintech (the Review). These reforms are part of a suite of legislative reviews launched by the UK government to enhance the competitiveness of the UK market in the…
In brief As previously discussed in our article on Brexit-related challenges for the life sciences sector dated 12…
The EU is reportedly set to approve its first round of sanctions against officials responsible for the military…
In an 18 March 2021 statement released by the German Foreign Ministry, the Group of Seven (G7) nations have announced that they remain fully committed to the implementation of sanctions on Russia over the annexation of the Crimean Peninsula. The group’s Foreign Ministers also reaffirmed their unwavering support for and…
On 22 March 2021, the UK Government added four individuals and one entity to the Global Human Rights financial…
Recently, there has been development in Spain in relation to value-added tax (VAT) refunds post-Brexit, and the application of a European Court of Justice case to recent tax court rulings around indemnity payments.
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.Â
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.
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.
A number of employment law changes are coming into force on 6 April 2021 that UK employers should make note of.Â
The UK has designated six individuals as subject to financial sanctions and asset freeze measures under the Syria (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/792). The designated persons are: Muhammad Bara AL-QATIRJI, Faisal AL-MIQDAD, Luna AL-SHIBL, Malik ALIAA, Yasser Hussein IBRAHIM, Zaid SALAH. Separately, two entries under the UK’s Iran (Nuclear) financial…