The CIOT has also responded to HMRC’s consultation on transfer pricing permanent establishment and diverted profits tax which closed on 7 July.
On transfer pricing and the general exemption for UK the UK transfer pricing is considered a positive change although questions have been raised about the exclusions for financial services transactions.
Concerns also remain around HMRC’s power to issue transfer pricing notices determining that there is a participation noting that: ‘the solution should be to ensure that the legislation is clear and does properly capture participation under Article 9 as intended. We do not think that it is appropriate for HMRC to have a power to fill in what they subsequently perceive to be gaps in the legislation.’ Further clarity is needed on the participation rules with particular regard to joint venture arrangements.
The UK definition of permanent establishment should be aligned...
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The CIOT has also responded to HMRC’s consultation on transfer pricing permanent establishment and diverted profits tax which closed on 7 July.
On transfer pricing and the general exemption for UK the UK transfer pricing is considered a positive change although questions have been raised about the exclusions for financial services transactions.
Concerns also remain around HMRC’s power to issue transfer pricing notices determining that there is a participation noting that: ‘the solution should be to ensure that the legislation is clear and does properly capture participation under Article 9 as intended. We do not think that it is appropriate for HMRC to have a power to fill in what they subsequently perceive to be gaps in the legislation.’ Further clarity is needed on the participation rules with particular regard to joint venture arrangements.
The UK definition of permanent establishment should be aligned...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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