Tolley's International Tax Planning

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Commentary

A constant in the international tax arena is an increasing pace of change. A significant proportion of FA 2019 was devoted to international measures, with some significant new measures such as the charge on offshore receipts in respect of intangibles (since amended further, indeed), the anti-profit fragmentation rules and revisions to the domestic definition of permanent establishment.

However, two substantial matters remain largely unresolved since the last edition. It is still not possible to set out the consequences of Brexit without engaging in speculation. Although we have seen reports and progress in the OECD’s work on the digital economy, with the development of the two pillars and the various options including user engagement, marketing intangibles, modified nexus and minimum taxation, a consensus is not yet in reach. However, of the countries which are at various stages of introducing unilateral measures, such as the Digital Services Tax, many are delaying their measures until 2020 when we expect the final report; we have therefore postponed detailed consideration of published measures which may still change. With the passing of time certain topics become more a matter of historical interest: we have continued to reduce the extent of the coverage of such historical items.

The cumulative changes to real estate taxation continue and the chapter is revised.

This edition is updated to April 2019.

SOURCE CURRENCY
2019/20 Edition

UPDATE INFORMATION

New to this edition:

For this current edition the pre-existing text has been reviewed and updated.
> Updated for Finance Act 2019

The cumulative changes to real estate taxation continue and the chapter is revised.

Each key topic is illustrated with short examples, tables and checklists.

AUTHOR INFORMATION
For 2019/20 Edition

AUTHOR:
Andrew Seidler, Ken Almand and
Adrian Benosiglio, RSM

Consultant Editor:
Robert Langston
Saffery Champness

Contributors

 Robert Langston Contributor