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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...
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...
Towards a "smart" VAT system? We live in a world of burgeoning automation. Transactions are increasingly automated in a range of ways, from direct debit (around since the early 1960s and still one of the most popular payment methods today) to smart contracts. However - in the UK at...
Robot delivery services: the latest in anthropomorphic marketing? Given the number of announcements this year from the likes of Starship, Segway, Ford and FedEx you would be forgiven for feeling surprised and perhaps a little dismayed that as the end of the year draws nearer, our streets are not yet filled with diligent...
Gibraltar companies outside the scope of the Parent-Subsidiary Directive On 24 October, Advocate General (AG) Hogan opined that a company incorporated, and subject to corporation tax, in Gibraltar cannot avail itself of the benefits of the Parent-Subsidiary Directive (PSD). On a more positive note for the taxpayer concerned,...
Consultation on the Global Anti-Base Erosion (GloBE) Proposal under Pillar Two Another day, another proposal to substantially change the international tax architecture.  This time it is the GloBE Proposal under Pillar Two. Pillar Two seeks to ensure that the profits of multinational enterprises are subject to a minimum tax rate by...
The ORIP rules: intangible property held in the Crown Dependencies It may be tempting to think that, following the renegotiation of the double tax treaties (DTTs) between the UK and the Crown Dependencies (Guernsey, the Isle of Man and Jersey), entities resident in one of them would fall outside the scope of the UK's...
US Treasury Department Loosens “Earnings Stripping” Rules The latest salvo in a years-long struggle to administer US “earnings stripping” rules took another turn on 31 October, when the US Treasury Department announced that it would loosen rules designed to limit the practice. “Earnings stripping” or “interest...
Filing tax returns becomes a high risk occupation In the 2020 Finance Bill, the Italian Government announced its intention to combat tax evasion, thought to cost more than 100 billion Euros a year to a national budget in constant deficit.   In these times of blaring proclamations, politicians are...
Tax on cryptoassets: HMRC’s latest guidance for business In December 2018, I wrote a blog about HMRC’s guidance for individuals on the taxation of cryptoassets. HMRC has, nearly a year later, followed up with guidance for business on the tax treatment of exchange tokens, such as bitcoin. The guidance notes that...
Dutch based in-house tax departments can be intermediaries under DAC6 As the 31 December 2019 deadline for the implementation of DAC6 into the national legislation of EU Member States draws closer, legislators across the EU little by little shed more light on the scope of application of DAC6.  In the most recent explanatory...
Discriminatory tax treatment of foreign Real Estate Investment Funds (REIFs) Are closed-ended Italian REIFs and open-ended REIFs in a comparable position for Italian indirect tax purposes? The ECJ is set to address this question within months (C-479/19). The request for a preliminary ruling was referred by the Italian Supreme...
Putting the ML into AML The FCA and Bank of England have recently published the findings of their first ever survey of the use of machine learning (ML) in financial services firms. The conclusions from the survey are that there has been significant uptake and deployment of ML in...
Conforming interpretation revisited The UK’s First-tier Tax Tribunal's decision in Panayi has been published. Whilst the case was reminiscent of Gallaher  (previously discussed by Sara Luder), the Judge reached what looks like an opposing conclusion.  Panayi  concerned a capital gains tax...
Freedom to move capital to (or from) overseas territories Transfers between the UK and Jersey are, according to the UK Supreme Court, within the scope of the freedom of movement of capital under what is now article 63 of the Treaty on the Functioning of the European Union.  Routier v HMRC concerned a potential...