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 […]
Chancellor confirms full expensing will be permanent
[ad_1] The full expensing regime will not expire on 31 March 2026 and will be made permanent, the Chancellor announced at the Autumn Statement on 22 November 2023. The full expensing regime allows companies to claim 100% capital allowances for expenditure on qualifying plant and machinery. This means that companies paying the main rate of […]
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 […]