Centre for Business Taxation

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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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Posted by: on December 13, 2017

Cleaning Up the U.S. Tax System?

The House and the Senate have passed tax reform bills in the U.S. The process has reminded me of how my 8-year-old son washes the dinner dishes: fast and without attention to detail. If you’ve ever had an 8-year-old, (or been an 8-year-old) you know what I mean. The bills are designed to fix America’s […]

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Posted by: on December 5, 2017

Report of the CBT Conference on “The Future of the Arm’s Length Principle”

On November 29, the Centre for Business Taxation (CBT) convened a conference in London on The Future of the Arm’s Length Principle (ALP) with speakers drawn from business, the OECD and academia. This was also an opportunity to mark the publication of a new book by CBT Associate Fellow Richard Collier and a previous head […]

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Posted by: on November 28, 2017

The Moral Law

The aftermath of the Paradise Papers affair continues to fill the airwaves and fuel ongoing discussion on tax, as seen in the Chancellor’s asides in the Budget Speech last Wednesday. Unfortunately, however, the overwhelming bulk of commentary struggles to reflect any serious understanding of the issues raised. The mishmash of stories and comments on the […]

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