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International update for June

International update for June

Tim Sarson’s latest summary of international developments.

Tim Sarson

Partner and Brexit Tax & Location Lead

KPMG in the UK


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The OECD’s approach to the challenges of the taxation of the digital economy has now been formalised by a road map agreed upon by the Inclusive Framework. The road map is a significant step forward and seeks to put the OECD on course to reach consensus on solutions to these challenges by the end of 2020 but significant obstacles remain. The UK Government has formally applied for an annulment of the European Commission’s decision following the state aid investigation into the controlled foreign company (CFC) group financing exemption. The UK is nonetheless obliged to start the process of recovery from taxpayers. HMRC have released their draft guidance on the offshore receipts from intangible property rules, together with proposed regulatory amendments and accompanying explanatory notes. The amendments have unexpectedly widened the scope of certain aspects of the rules and some of the relieving measures do not go as far as taxpayers may have hoped.

In the latest of his regular articles for Tax Journal*, Tim Sarson rounds up recent international developments. This month’s article looks at:

  • Taxation of the digital economy;
  • The OECD secretary general’s report to G20 finance ministers;
  • UAE and Russia ratifying the MLI;
  • UK appeal against CFC companies state aid decision;
  • Offshore receipts from intangible property; and
  • UK profit diversion compliance facility: second round of nudge letters.

* First published in Tax Journal on 28 June 2019. Reproduced with permission.

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