A round up of other news this week.
The OECD has confirmed that the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS will enter into force on 1 July 2018, following the deposit of the fifth instrument of ratification by Slovenia on 22 March 2018.
As previously mentioned in Tax Matters Digest, HMRC have updated their corporate interest restriction (CIR) guidance to confirm the way in which groups can make elections outside of a return. Any elections outside of the interest restriction return should be sent to a group’s Customer Compliance Manager (CCM). If the group does not have a CCM they should be sent to Wealthy and Mid-sized Business Compliance, HM Revenue and Customs, BX9 1BN, United Kingdom.
The 2018 UK-Cyprus Double Taxation Convention was signed on 22 March 2018 in Nicosia and is not yet in force.
The OECD has released additional guidance on the attribution of profits to permanent establishments (PEs), setting out high-level general principles for attributing profits to PEs in accordance with applicable treaty provisions. It also provides examples on the attribution of profits to certain types of PEs arising from the changes to the PE definition under BEPS Action 7.
HMRC have published guidance on SDLT for cross border transactions.
Guidance on the operation of tax reliefs in the UK when Scottish Income Tax rates and bands change in April 2018 has been published.
HMRC have published Spotlight 43 on the ruling by the ASA that advertising in relation to certain SDLT tax avoidance arrangements was misleading.
Rob Smith, banking partner, KPMG UK comments on the 2018 stress test scenario. The Bank of England took the decision to leave the scenario unchanged which was unexpected, but it shows potential concerns with the effects of the new accounting standard IFRS9 and its behaviour under stress.
Speaking ahead of the recent meeting between David Davis and Michel Barnier, James Stewart Head of Brexit at KPMG UK, commented, “Political agreement on transition alleviates some pressure on some companies, but it would be a mistake to think it solves the Brexit readiness problem”.
And finally… Tax Matters Digest will be taking a break next week for the Easter bank holidays. We’ll return on 9 April as usual.