Other news in brief

A round up of other news this week.

A round up of other news this week.

Each year HMRC undertake a review of the UK’s double taxation treaties (DTTs) in conjunction with key stakeholders. The 2023/24 review has now been launched and seeks stakeholders’ views on priority issues for negotiation and renegotiation in relation to the UK’s DTTs for 2023 and beyond. In their request for comments, HMRC note that following Brexit they will continue to prioritise the renegotiation of DTTs with European countries to try and replicate the benefits of the Interest and Royalty and Parent Subsidiary Directives. Responses are requested by 25 November 2022 and a virtual meeting to discuss the issues raised will be held in December. If there are any points you wish KPMG in the UK to consider including in the submissions we intend to make, please contact Phil Roper.

HMRC have published a technical consultation seeking views on draft regulations to implement the OECD’s Model Reporting Rules for Digital Platforms. The rules will require UK platform operators to collect, verify and report certain details of sellers who work on their platform to HMRC, and provide a copy of the reported information to sellers. HMRC will then exchange the information they collect with other tax authorities and use it to detect non-compliance by sellers. The draft regulations set out further details of the actions digital platforms will need to take to comply with the rules, penalties for failure to comply, and the appeals process. HMRC have also extended their scope to include the sale of goods and transport rental as a result of the consultation responses. The consultation will close on 13 December 2022 and final regulations are expected to be made in early 2023 to come into force on 1 January 2024.

On 6 October 2022, the OECD released a report entitled ‘Tax Incentives and the Global Minimum Tax: Reconsidering Tax Incentives after the GloBE Rules’. The report’s key message is that now is the time for jurisdictions to assess their current tax incentives in preparation for the arrival of Pillar Two. In a recent report from KPMG international, KPMG tax professionals from around the globe share their initial observations and argue that although the OECD report is focused on what governments should do, now is the time for businesses to consider the incentives they are experiencing and whether they are effective in a post-Pillar Two world.

On 24 October 2022, the Dutch Ministry of Finance launched a consultation on draft legislation and explanatory notes to implement Pillar Two of BEPS 2.0 in the Netherlands. The rules under Pillar Two would establish a global minimum tax of 15 percent for multinational enterprises with a turnover of at least €750 million. The consultation follows the statement issued on 9 September 2022 by the Netherlands, together with France, Germany, Spain, and Italy, expressing their commitment to implementing the global minimum tax in 2023. Read more in a recent Tax Flash from KPMG in the Netherlands.