Changes to transfer of assets abroad rules
[ad_1] New legislation announced in the Budget will prevent individuals from using a company to bypass the transfer of assets abroad (TOAA) anti-avoidance provisions. Changes to the TOAA rules will apply to income arising to persons abroad on and after 6 April 2024. It follows the Supreme Court decision Commissioners for HMRC v Fisher [2023] […]
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 […]