This week we bring you news of a change in the UK’s Country by Country (“CbC”) reporting rules, and HMRC has provided a note on the VAT place of supply rules in the context of education and training. A warning has been issued about a new type of phishing scam, and HMRC has changed its approach to appointing reporting companies under the Corporate Interest Restriction legislation. Agent Update: issue 110 is also available. And finally, the form to acquire overlap relief information from HMRC in the context of basis period reform, which we told you about a few weeks ago, is expected to be launched by HMRC on 29 August.
CbC reporting notification requirement removed
As a result of The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) (Amendment) Regulations 2023, companies within the UK are no longer required to make an annual CbC reporting notification stating which legal entity within the Multinational Enterprise (“MNE”) is the Ultimate Parent Entity, and will be filing the CbC report.
This applies to both UK-headed MNEs with a consolidate group revenue of €750 million or more, and UK resident entities of non-UK MNEs who are required to complete the notification in the UK on behalf of their parent entity. This change in legislation took effect from 26 July 2023.
HMRC’s Joint VAT Consultative Committee (“JVCC”) paper on the VAT place of supply rules and education and training
HMRC’s JVCC, of which Chartered Accountants Ireland is a member, has responded to a query on the place of supply rules in the context of education and training services. The paper sets out the treatment of the various types of education services and confirms how HMRC sees them being treated for the purposes of the place of supply rules. Read the full email from HMRC.
HMRC warning about new phishing scam
HMRC has recently detected a new criminal phishing scam offering people tax rebates by email, and have posted a warning on its various digital media channels:-
Corporate interest restriction — HMRC no longer appointing reporting company
Companies impacted by the corporate interest restriction (“CIR”) legislation are able to appoint a ‘reporting company’. This company is then required to submit the CIR return which must be submitted within 12 months of the end of the reporting period.
In a recent update to the CIR guidance, if a company does not nominate a reporting company by the required deadline (usually 12 months from the end of the accounting period), HMRC is no longer appointing the reporting company.
The reporting company must be:-
- liable to UK Corporation Tax;
- non-dormant; and
- authorised by at least 50 percent of the group’s non-dormant companies (which are liable for UK Corporation Tax) to be appointed as the reporting company.
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