A round up of other news this week.
The UK deposited its instrument of ratification with the OECD on 29 June 2018. This means that the date of entry into force for the UK will be from 1 October 2018. The MLI should therefore generally be expected to have effect for Covered Tax Agreements with other states for which the MLI is in effect from 1 January 2019 for WHT and for all other purposes, on the UK side, from 1 April 2019 (5 April for income tax), subject to the optionality within the treaty (and the position for the other contracting state to the Covered Tax Agreements). Other countries which have ratified before 30 June are Austria, Isle of Man, Jersey, New Zealand, Poland, Serbia, Slovenia and Sweden.
The taxpayer in Lomas & Ors v HM Revenue and Customs has been granted leave to appeal to the Supreme Court in a case concerning whether statutory interest paid to creditors in insolvency proceedings is ‘yearly interest’ such that there is an obligation to deduct the basic rate of income tax. Whilst the case is limited to statutory interest, it explores important interpretative points on the general definition of ‘yearly interest’.
The OECD has published a new set of bilateral exchange relationship agreements on 5 July 2018. Over 90 jurisdictions are now covered by the Common Reporting Standard Multilateral Authority Agreement (CRS MCAA), with the remaining committed jurisdictions expected to follow over the summer.
The updated UK-Bermuda Tax Information Exchange Agreement (TIEA) has been published.
Commenting on the latest manufacturing PMI figure (54.4), Justin Benson, UK Head of Automotive at KPMG UK said that this figure is relatively low when compared to recent months, but it is still well above 50, demonstrating continued expansion of the sector.