Consultation

UK Royalties Withholding Tax – Consultation

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Source: HMRC Press Release, 1 December 2017

This consultation relates to the circumstances in which royalties and other types of payment made to connected persons not resident in the UK have a liability to income tax.

The UK government will introduce legislation in Finance Bill 2018-19 that broadens the circumstances in which certain payments made to non-UK residents have a liability to income tax.

These changes will have effect from April 2019. The consultation focuses on the design of that legislation.

The government welcomes comments from those who would be affected by these changes, including companies, advisors and representative bodies.

The consultation runs from 1 December 2017 to 23 February 2018.

Details of the Consultation here

 

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TP Secondary Adjustments, UK Consultation (updated article)

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UK Transfer Pricing Consultation – Secondary Adjustments – updated with a summary of the Consultation questions

The UK government is consulting on whether a secondary adjustment rule should be introduced into the UK’s transfer pricing legislation and how that rule would be designed.

The UK’s preference is for a rule which treats the non-arm’s length element of the transfer price as a deemed loan from the UK company to the connected party, with interest imputed at a rate above the market rate, for deterrent effect. The rule would be triggered for primary adjustments above a certain threshold, for example above £1m.

The consultation opened on 26 May 2016 and closes on 18 August 2016 at 11:45pm

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UK Transfer Pricing Consultation – Secondary Adjustments

Posted on Updated on

This is a consultation on whether a secondary adjustment rule should be introduced into the UK’s transfer pricing legislation and how that rule would be designed.

The UK government’s preference is for a rule which treats the non-arm’s length excess as a deemed loan from the UK company with interest imputed at an above-market rate (for deterrent effect). The rule would be triggered for primary adjustments above a certain threshold, e.g. above £1m.

Read the rest of this entry »