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International business operating models: the tax issues

Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the tax risks to international business operating models.

In the last five years there has been an ever-increasing focus on the taxation of multinationals fuelled by a global drive to increase transparency improve the cohesiveness of corporate tax across territories and critically to align taxation with value creation. Amid growing pressure from multiple stakeholders the OECD’s BEPS project initiated in 2015 was the catalyst for change and its recommendations on 15 actions have underpinned significant global legislative change.

There are a host of provisions that multinationals (MNCs) operating in the UK must navigate. These include:

  • the EU Anti-Tax Avoidance Directive (ATAD) which implements the BEPS recommendations in the EU;
  • US tax reform; and
  • unilateral UK measures including diverted profits tax (DPT) anti-hybrid rules (implemented ahead of EU...

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