ACCA welcomes the opportunity to comment on the position page on corporate tax and the digital economy as issued by HM Treasury.
The UK government's position, that in principle a multinational group's profits should be taxed in the countries in which it generates value, appears uncontroversial.
However there is a fine but important distinction between that principle and the practice of what currently happens. A multinational group's profits are taxed in those companies in which they are accounted for, subject to limited adjustment (including cross-border transfer pricing adjustments) for tax purposes. Reconciling the general policy statement with existing reporting and assessment tools in a fashion which would not create significant uncertainty for business would be a significant accounting and legal drafting challenge.
Our detailed comments can be found in the attached document.