OECD consults on definition of permanent establishment
[ad_1] The OECD seeks to provide clarity on what constitutes a permanent establishment for activities in connection with the exploration or exploitation of extractible natural resources. The most significant feature of the proposed additions to the OECD’s model tax convention commentary is a lower threshold for when a permanent establishment (PE) is deemed to be […]
HMRC asks VAT businesses to prove UK establishment
[ad_1] Businesses registered for VAT at a high-volume address will be asked by HMRC to prove they are established in the UK. Online marketplaces have been liable for the output VAT from sales on their platforms by overseas traders since January 2021. HMRC believes that some non-established taxable persons (NETPs) have incorporated in the UK […]
DPT, transfer pricing and permanent establishment reforms
[ad_1] ICAEW’s Tax Faculty welcomed HMRC proposals to make the UK legislation more closely aligned with OECD principles, but noted that there were good reasons to not fully adopt the OECD’s 2017 changes to the permanent establishment definition. HMRC’s consultation document, published on 19 June 2023, contains proposals for the reform of transfer pricing, the […]