Taxand UK Diverted Profits Tax workshop
Taxand UK hosted a workshop to explore the new diverted profits tax. This measure was announced in the Autumn statement with some new post-consultation draft clauses published on 20 March 2015 and a final draft published in the Finance Bill on 24 March 2015.
The new tax applies to profits diverted after 1 April 2015, and whilst aimed in particular at non-UK technology groups operating in the UK, it’s wide reach will mean a lot of UK based groups will need to satisfy themselves that they are not inadvertently caught.
The workshop covered the following areas:
- brief overview of the diverted profits tax, the structures it was aimed at and an update on what has changed since it was first announced;
- circumstances which might be caught beyond the original target;
- the interaction with the transfer pricing and CFC rules; and
- how a group might satisfy itself that it does not need to notify and other practical implications