Tax News Highlights - May 2021

In this podcast, Zoe Andrews and Tanja Velling provide an update on the progress of Finance Bill 2021, noting some of the Government amendments made during the Committee Stage.

They also discuss two First-tier Tribunal and one High Court decisions. The First-tier Tribunal decisions are those in Euromoney on the application of the purpose test in section 137 of the Taxation of Chargeable Gains Act 1992 to prevent rollover treatment on a share-for-share exchange and in Aozora on the interaction between the UK’s rules on unilateral relief from double taxation and the Limitation on Benefits article in the US/UK tax treaty. The High Court decision concerns the Danish tax authority SKAT’s attempt to reclaim Danish withholding tax refunds.

The podcast further covers certain international tax topics. Zoe and Tanja consider the impact of the Biden/Harris administration’s tax reform proposals on the OECD’s international tax reform project, the adoption of a new Article 12B (Income from Automated Digital Services) for the UN’s Model Tax Treaty and the consultation on proposed changes to the commentary on Article 9 (Associated enterprises) of the OECD’s Model Tax Treaty.