UK Diverted Profits Tax Guidance Released

By Robert Robillard - 1 April 2015

This blogpost originally appeared on rbrt.ca.

On March 30, 2015, HM Revenue & Customs released the interim draft guidance on the diverted profits tax.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, Adm.A., MBA, M.Sc. Econ., M.A.P.
Senior Partner, RBRT Inc.
514-742-8086; robertrobillard “at” rbrt.ca
www.rbrt.ca

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