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Posted by: on April 30, 2019

Does the Tax System Offer an Effective Tool to Support Innovation and R&D?

The process of innovation is rarely swift and problem-free. Progressing from an innovative idea in the course of a research and development (R&D) programme through the stages of prototype, production, marketing and ultimately a successful sales strategy is fraught with difficulty, even when the invention is truly novel and potentially a boon to the world. […]

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Posted by: on March 27, 2019

A Reform Option for the OECD: Residual Profit Allocation by Income

The recent OECD consultation, notionally on the tax challenges brought by the digitalisation of the economy, has resulted in over 230 responses, from ACCA to Zalando. If it were just about new rules for a handful of large digital companies, that would be surprising. But it is not. The changes afoot go right to the […]

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Posted by: on December 18, 2018

The WTO as Tax Scarecrow?

  Over the past years, a broad range of tax measures have faced criticism due to their alleged incompatibility with the law of the World Trade Organization (WTO). In 2016, when the United States considered moving from traditional corporate income taxes to destination-based taxes, some tax academics argued that the proposal was contrary to WTO […]

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Posted by: on December 3, 2018

It’s far too complicated, but who cares!

The international tax system is too complicated.  Is it even right to call this dishevelled, mountainous conglomeration a “system”? The combination of complex and rapidly expanding domestic law, the ever-increasing complexity of international business exacerbated by digitalisation, and the growing number of domestic tax disputes is leading to ever greater uncertainty for business.  Heaped over […]

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Posted by: on October 23, 2018

The Digital Services “Sutton” Tax

The American bank robber Willie Sutton is best remembered for an answer (which he claimed never to have given) to the question “why do you rob banks?”. The answer was “that’s where the money is”. I’d like to suggest that proposals – from HM Treasury, the EU, and others – for a digital services tax […]

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Posted by: on May 2, 2018

Our Response to Tax Fraud is Endangering the Rule of Law

Last month the UK Parliament’s Treasury Select Committee announced the launch of three new enquiries on different aspects of tax enforcement.  Whilst the enquiries will address tax avoidance concerns, the biggest emphasis is on tax fraud and enforcement.  This is very welcome.  Whilst tax policy tends to get the headlines tax enforcement is fundamental for […]

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Posted by: on March 26, 2018

The Arm’s Length Principle (“ALP”) – Is it a Principle and is it Arm’s Length?

THE ARM’S LENGTH PRINCIPLE (“ALP”) – IS IT A PRINCIPLE AND IS IT ARM’S LENGTH? What is the ALP? The definitive statement of the ALP is set out in Article 9 (1) of the OECD Model Double Tax Treaty. Broadly, this tells us that where “conditions are made or imposed” between associated enterprises in their […]

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Posted by: on February 21, 2018

Taxing Digital Business: a Plea for Holistic Thinking

There is widespread political agreement that tax reform is needed to address the problems that digitalisation poses to business taxation, as recently evidenced by the EU Commission’s Communication and HM Treasury’s Position Paper on the issue. The OECD is expected to publish an interim report on digitalisation in April 2018. We will comment on these […]

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Posted by: on January 26, 2018

Taxing pollution across borders: an innovative proposal?

Taxing pollution across borders: an innovative proposal?   Around one year ago, Lakshmi Mittal – the chairman of ArcelorMittal – published an opinion piece in the Financial Times, in which he called for the adoption of a “carbon border tax” in Europe. Around the same time, the Climate Leadership Council – a US-based conservative organization […]

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Posted by: on January 18, 2018

Relief for First-Time Buyers

The Autumn Budget 2017 announced a reduction in stamp duty for residential properties under £500,000 purchased by first-time buyers. But how much will first-time buyers actually benefit? Existing research suggests only 60% of the gain from this reduction will go to the buyer. Some first-time buyers should benefit more than others – for example, those […]

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