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Fortnight to 12 July 2018

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK.

Finance Bill 2018-19: government releases draft legislation
On 6 July the Government published a number of policy announcements and draft clauses (subject to consultation closing on 31 August) intended for inclusion in Finance Bill 2018-19 which is expected to be introduced towards the end of this year following a Budget Statement in November. A number of these proposals, including measures relating to the CFC partial exemption and the introduction of other changes to implement ATAD (the EU’s Anti Tax Avoidance Directive), are of particular interest in the international and treasury tax arena.  Read more in this HMRC news story.

UK ratifies BEPS multilateral instrument (MLI) on tax treaties
The UK deposited its MLI ratification instrument and final positions (opt-ins and opt-outs) with the OECD on 29 June 2018. This means that the MLI will come into force for the UK on 1 October 2018. Determining when the MLI will begin to modify the impact of the UK’s double tax treaties, and how it will do so, is more complex.  Read more here.

The future relationship between the United Kingdom and the European Union
The Department for Exiting the European Union has published its policy paper on the future relationship between the United Kingdom and the European Union.