UK Diverted Profits Tax Guidance Released
On March 30, 2015, HM Revenue & Customs released the interim draft guidance on the diverted profits tax. It is available here.
A Summary of amendments following the technical consultation has also been published and is available here. The summary pertains to the following:
- Narrowing the notification requirement;
- Clarifying rules for giving credit for tax paid;
- Clarifying the meaning of “excluded loan relationship”;
- Simplifying the legislation by restructuring and clearer signposting;
- Clarifying the economic substance test;
- Clarifying the operation of the rule to address avoidance of a UK taxable presence (Permanent Establishment);
- Exclusion of charities and other exempt bodies;
- Application to land and property; and
- Application to oil and gas ring fence regime.
Robert Robillard, Ph.D., CPA, CGA, MBA, M.Sc. Econ.
Senior Partner, DRTP Consulting Inc.
514-742-8086; robertrobillard “at” drtp.ca
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