OECD meaning

ARCHIVED : This flowchart has been archived and is not maintained. STOP PRESS : On 28 March 2023, the disclosable arrangements (DAC 6) legislation was superseded by the Mandatory Disclosure Rules (MDR) legislation. The DAC 6 rules and accompanying HMRC guidance have now been formally withdrawn. As noted in Practice Note: Disclosable cross-border tax arrangements—DAC 6 [Archived], the reach of the UK’s disclosure rules was markedly narrowed with effect from IP completion day (11 pm on 31 December 2020). The residual disclosure rules were then wholly replaced on 28 March 2023 by fresh legislation designed to implement the OECD Mandatory Disclosure Rules (MDR), as contained in The International Tax Enforcement (Disclosable Arrangements) Regulations 2023, SI 2023/38 (MDR regulations). Although the DAC 6 regulations, SI 2020/25, were revoked with effect from 28 March 2023, they continue to apply to arrangements that were entered into before that date...

Stop Press: Section 49 together with Schedule 7 to the Finance Act 2026 revises the UK’s domestic rules concerning UK permanent establishments of overseas, non-UK companies, applying for accounting periods (for corporation tax) or tax years (for income tax) that start on or after 1 January 2026. These measures update both the meaning of a UK permanent establishment and the framework for attributing profits to such establishments so as, in each instance, to align them more closely with the OECD Model Tax Convention. This ensures the domestic position is more consistent with internationally accepted norms. Separately, Section 46 and Schedule 5 to the Finance Act 2026 scrap the DPT regime and introduce the ‘unassessed transfer pricing profits’ (UTPP) provisions, effective for accounting periods commencing on or after 1 January 2026. HMRC has published a new chapter in the International Manual setting out guidance on the UTPP rules at INTM489100. Additional practical guidance is provided there. For further detail on these updates, see News Analysis: Budget...

This Table This table summarises the hallmarks for the Mandatory Disclosure Rules (MDR), in force from 28 March 2023, which implement the Organisation for Economic Co-operation and Development (OECD) model rules in the UK and, from the same date, entirely repeal EU Directive 2018/822 (DAC 6) in the UK. It is intended to be consulted alongside the main Practice Note: Disclosable cross-border tax arrangements—Mandatory Disclosure Rules (MDR). The generic hallmark for a Common Reporting Standard (CRS) avoidance arrangement covers any arrangement where it is reasonable to conclude it was structured to circumvent CRS legislation, or has been promoted as doing so, or achieves that effect...

This Flowchart has been archived and is not maintained. Please be aware the patent box computation was revised for fresh claims from July 2016 to align with the framework for preferential intellectual property regimes established under the OECD BEPS project...

Mandatory Disclosure Rules (MDR) for Common Reporting Standard (CRS) Avoidance Arrangements and Offshore Structures In March 2018, the Organisation for Economic Co-operation and Development (OECD) issued the model Mandatory Disclosure Rules (MDR) for Common Reporting Standard (CRS) avoidance arrangements and offshore structures, intended to encourage country by country consistency in applying disclosure and transparency so as to combat aggressive tax planning on a global scale...

In this issue: King’s Speech 2024 Criminal procedure and evidence Sentencing Bribery, corruption, sanctions and export controls Cybercrime and data protection offences Environmental offences Food safety and hygiene offences Fraud, forgery, tax and theft offences Health and safety and corporate manslaughter offences Local authority prosecutions Corporate Crime in Scotland Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information King’s Speech 2024 King’s Speech 2024—criminal justice and law enforcement His Majesty the King outlined the government’s priorities and intended policies for the forthcoming parliamentary session at the State Opening of Parliament on 17 July 2024. As in November 2023, public safety was central to the address, and the new Prime Minister, Keir Starmer, pledged to clamp down on anti‑social behaviour, reclaim our streets and protect our borders. To achieve this, he set out plans to bolster policing and the criminal justice...

In this issue: Budgets and Finance Bills VAT Taxes management and litigation Individuals and income tax International Employment taxes Real estate tax LexTalk®Tax: a Lexis®Nexis community Daily and weekly news alerts Dates for your diary Trackers New and updated content Useful information Budgets and Finance Bills Finance Bill 2026 completes House of Commons committee stage On 3 February 2026, the Public Bill Committee concluded scrutiny of Finance Bill 2026 after just six of the scheduled 14 sittings. The Bill has been reissued to fold in government amendments cleared in committee, bringing the Commons committee phase to a close. The revised Bill will proceed to report stage in the Commons—date to follow—which is Parliament’s last chance to make substantive changes. The Commons recess runs from 13 to 20 February, with business resuming on 23 February. See: LNB News 04/02/2026 19 and Tax—Finance Bill 2026 tracker—progress through Parliament. National Insurance Contributions...

In this issue: Employment taxes VAT International Individuals and income tax Taxes management and litigation Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Employment taxes Appeal court rules that loans advanced through a remuneration trust were chargeable as disguised remuneration and that the linked costs were non-deductible (Marlborough DP Limited v HMRC). In Marlborough DP Ltd, the Court of Appeal dismissed the taxpayer’s case and upheld the Upper Tribunal (UT). It found that amounts lent to a director under a remuneration trust fell within the disguised remuneration regime in Part 7A of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003), as they were made in connection with employment. The Court further concluded that the associated payments were not allowable for corporation tax, since they were not incurred wholly and exclusively for the purposes of the company’s trade. See News Analysis: Court of Appeal...

FORTHCOMING CHANGE relating to the future withdrawal of DST : Following OECD-led talks that produced a political accord on a two‑pillar solution in October 2021, the UK reached an understanding with the US, Austria, France, Spain and Italy to move away from DST towards the new global tax regime, using a transitional DST credit system. Under the arrangement, the UK would retain DST receipts until Pillar One became operational and, once in force, companies could credit against future UK corporation tax the difference between DST paid from January 2022 and the amount that would have arisen had Pillar One applied instead. In exchange, the US, which regards digital services taxes as discriminatory towards US companies, agreed to withdraw proposed retaliatory tariffs on certain US imports from the other five countries, and undertook not to pursue additional trade measures against those states because of their digital services taxes until the interim period concluded. This understanding was subsequently extended by all six countries to 30 June 2024, from an original end...

Stop Press: Section 49 and Schedule 7 of the Finance Act 2026 revise the UK’s domestic rules on UK permanent establishments of non-UK companies, applying to accounting periods (for corporation tax) and tax years (for income tax) that start on or after 1 January 2026. The measures update both the definition of a UK permanent establishment and the methodology for attributing profits to a UK permanent establishment, each intended to align more closely with the OECD Model Tax Convention. They also adjust how the investment manager exemption operates. For further details, see News Analysis: Budget 2025—Tax analysis — International. A non-UK resident company trading in the UK may either incorporate a UK subsidiary or trade through a permanent establishment (PE), commonly a branch. This Practice Note sets out the key UK tax considerations relevant to that choice, while recognising that tax is only one of several matters to be weighed...

The Bribery Act 2010 (BA 2010) Enacted to secure the UK’s adherence to the Organisation for Economic Co-operation and Development’s (OECD) Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, the Bribery Act 2010 (BA 2010) delivers an effective framework to address corruption across public and private spheres, updating the UK’s anti-corruption regime and supplanting Prevention of Corruption Act 1906 and Prevention of Corruption Act 1916. BA 2010 carries significant consequences for any company incorporated in, or trading from, the UK. Its global reach covers bribery undertaken by a business, or by third parties acting for it, regardless of where in the world the conduct occurs...

To be completed by [ insert name of organisation appointing the agent/intermediary ]... 1 Geographical factors Consider the location of the agent or intermediary. Country where the agent or intermediary is located [ Insert country ] That country’s Transparency International Corruption Perceptions Index score [ Insert score ] Is there credible reason to believe that business in this country is often secured through bribery of officials and/or that such payments are commonplace? If yes, give particulars, including how this came to your attention, for example via other multinational organisations operating there, local contacts, periodicals or news reports. ☐ Yes—[ Insert requested details ] ☐ No Have enquiries been made into the relevant civil/criminal law of the country to identify any material differences from UK law (eg legality of facilitation payments)? ☐ Yes ☐ No—[ Insert details ] Is the country known or reasonably suspected to: —operate high levels of secrecy; —be used as a tax haven; —not subscribe to the Common Reporting Standard;...

[ Insert organisation name ] has signed up to [ insert details of any environmental initiatives to which the organisation is a signatory, eg the United Nations Global Compact or the Science Based Targets initiative ]. The organisation is dedicated to advancing environmental sustainability and reducing negative environmental effects arising from our operations. We actively support global environmental aims, including the United Nations Sustainable Development Goals (SDGs). This policy sets out our pledge to responsible environmental stewardship, in line with international standards and best practice. 1 What are environmental impacts? ‘Environmental impacts’ are those described in ISO 14001, the UN Global Compact, and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. Under ISO 14001, environmental impacts mean any alteration to the environment, whether beneficial or adverse, resulting from an organisation’s activities, products, or services. Illustrative environmental impacts include: Climate change—energy consumption, transport, and greenhouse gas emissions from operations substantially drive global warming; Resource depletion—the use...