Archive | December, 2014

Falling Oil and Commodity prices – the tax consequences and impact on BEPS

The UK Office for Budget Responsibility has a fascinating simulation about the impact on Scotland’s finances of the fall in the oil price. Tax revenues would have fallen to a quarter of the 2016-2017 forecast made at the time of the referendum. Scotland would have looked at a much larger deficit in 2016/7 than the […]

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The end of the Energy Tax Directive and Cheap Oil

I was struck by the contrast between Lord Stern’s comments on the impact of cheap oil and the fate of the Energy Tax Directive. Lord Stern is quoted as saying “this is exactly the right moment to remove fossil fuel subsidies and intensify carbon pricing” and I completely understand why he says this. Consumers and […]

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The UK’s New tax on “diverted profits” – some issues for business

The UK is consulting on the provisions of a new provision to tax diverted profits with effect from 1 April 2015. It is worth quoting the description in full: “The diverted profits tax is a new charge on diverted profits. The main objective is to counteract contrived arrangements used by large groups (typically multinational enterprises) […]

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A “Google tax” or are royalty arrangements “artificial avoidance”?

The Autumn Statement in the UK on 3 December saw the announcement of a “Google Tax” to come into effect on 1 April 2015 (no it’s not a joke). Details are sketchy but its described as “25% tax on profits generated by multinationals that are shifted out of the UK”. I thought I would put […]

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