Two weeks to 7 February 2020
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK.
Brexit insights
The UK has left the EU, but that’s not the end of the Brexit story. As negotiations on the future trading relationship of the UK and the EU start, and trade discussions begin with countries around the world, how will you remain agile to respond to the risks and opportunities this new world presents? Visit our Beyond Brexit webpage for the latest updates. In particular please note:
Late payment interest on intra-EU loans or royalties - updated HMRC guidance
Following the CJEU’s decision in the Bulgarian case TTL EOOD, HMRC considers that it is precluded under EU law from charging late payment interest which arises on intra-EU loan transactions or royalties where the application of a double tax agreement results in no or a reduced rate of income tax. HMRC will however continue to consider applying penalties for failing to make a return where treaty clearance has been obtained after the interest or royalties have been paid. See HMRC’s guidance here.
HMRC publish Transfer Pricing/Diverted Profits Tax statistics
HMRC’s recently published statistics for TP/DPT covering 1 April 2018 to 31 March 2019 confirm that tackling profit diversion remains a priority area for HMRC. Our Tax Disputes and Transfer Pricing specialists comment on this article here and here respectively.
