Dominic Robertson (Slaughter and May) reports on the likely changes needed to group structures in light of BEPS, state aid challenges and the diverted profits tax
At the start of 2015 many groups will be planning any reorganisations they need to put in place over the next year. As ever both tax and non-tax factors (commercial regulatory etc) will drive these reorganisations. On the tax front I expect that five main factors are likely to prompt changes to group structures over the next few years.
Corporate tax has scarcely been out of the news for several years and significant public pressure has been applied to the corporate tax practices of big business. For example ActionAid published research in 2011 and 2013 listing...
