Source: Deloitte Global Transfer Pricing Alert 2017-033
“The first country-by-country (CbC) reporting notifications required to be made to the UK tax authorities are due by 1 September 2017.
This deadline applies to all reporting periods that end on or before 1 September 2017.
After 1 September 2017, the standard UK notification date is the end of the CbC reporting period.
A few examples regarding the application of these rules follow.
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Source: Crowe Clark Whitehill via Mondaq, 18 July 2017
“There has been much debate about whether Brexit will have a positive or negative impact on the UK’s international trade. For many, leaving the EU presents many questions to which the answers are unclear. But, in the continuous mist of uncertainty there could be a potential bright side to Brexit, where international trade zones are concerned, in the form of Free Trade Zones.”
“Free Trade Zones are widely used across the world, particularly in the US, South America, Canada, Middle East and Asia. The precise format varies, but it is very common for governments to use Free Trade Zones to encourage local manufacturing. They can also be used to simplify, or remove, import and local tax obligations for goods that are imported into the zones for manufacturing or processing.”
Robert Marchant, of Crowe Clark Whitehill, says “Clearly, the establishment of Free Trade Zones themselves will only help the UK economy if the port infrastructure is in place to support and assist UK manufacturers. A quick internet search shows that the UK is one of Europe’s biggest importers and exporters and my clients tell me that the UK has excellent port facilities; which suggests that the infrastructure is in place and could therefore be a platform for the creation of UK Free Trade Zones.”
Source: Arnold & Porter Kaye Scholer LLP, via Mondaq, 19 July 2017
“The UK Supreme Court has overturned existing case law to, for the first time, formally recognise a “doctrine of equivalents”, resulting in a broader scope of patent protection under UK law. This new approach is more patentee-friendly and brings the UK into closer alignment with courts elsewhere in Europe and in the US.
Historically the English courts have held that the wording of the claim is decisive when determining whether a patent is infringed, resulting in a relatively narrow scope of protection. The Supreme Court held that this approach placed too much weight on the words of the claim and did not provide fair protection for patent holders. Fair protection requires a broader scope of protection, extending beyond the wording of the patent claims to also cover products which are technically equivalent. In the case at hand, the Supreme Court held that Eli Lilly’s patent claims covering “pemetrexed disodium” would be infringed by Actavis’ products containing various alternative forms of pemetrexed, which did not fall within the wording of the claims, properly interpreted, but were nonetheless technically equivalent.” Read the rest of this entry »
Source: HMRC Press Release 3 July 2017
The Office of Tax Simplification (OTS) has responded to calls for UK Corporation Tax to be modernised and simplified in its report Simplification of the Corporation Tax Computation published 3 July 2017.
The report looks at four broad themes
- simpler tax for smaller companies
- aligning the tax rules more closely with accounting rules where appropriate
- simplifying tax relief for capital investment
- a range of further issues affecting the largest companies