permanent establishment

New UK/Austria tax treaty is signed

A new double tax agreement between the UK and Austria was signed on 23 October 2018. Subject to both countries having completed their parliamentary procedures and exchanged diplomatic notes, it will to come into force for the fiscal year beginning...

UK land trading and development

Finance Bill 2016 will contain new rules taxing profits from trading in and developing UK property, effective from the date when they are included in the Bill at the Committee Stage. HMRC opened consultation on the content of the provisions...

Diverted Profits Tax Guidance Issued

HMRC has issued guidance in respect of the Diverted Profits Tax (DPT), replacing the interim guidance issued in March 2015. DPT was introduced by Finance Act 2015, and applies from 1 April 2015.   Key points to note about DPT ·        ...

BEPS Action 7 (PE): We are not there yet….

The OECD reached an important milestone of its work on Action 7 [Prevent the Artificial Avoidance of Permanent Establishment (PE) Status] of the Action Plan on Base Erosion and Profit Shifting (BEPS). On 15 May, public comments are invited on a new...

BEPS Action 7 – More Questions than Answers

On 21 January, the OECD held a public discussion meeting on BEPS Action 7 focusing on preventing the artificial avoidance of permanent establishment (PE). Action 7 is one of the most discussed action points of the BEPS Action Plan and...

BEPS: Permanent Establishment- the Next Chapter

OECD/BEPS: Release of discussion draft on Action 7 (Prevent the Artificial Avoidance of PE Status) of the BEPS Action Plan  On 31 October 2014, OECD has invited invited public comments on a discussion draft which includes the preliminary results of...

BEPS Action Plan – The Ambitious Programme

This September will be a very exciting period for the international tax world and it is expected that the BEPS project marks its first turning point in the history of international co-operation on taxation. Pascal Saint-Amans, Director of OECD Centre...