Mark Middleditch (Allen & Overy) provides the monthly round-up of tax developments affecting the City
With measures including accelerated payments and high-risk promoters 2014 will not be remembered for well considered legislation operating equitably between taxpayers and HMRC. The worst measure was probably best left to last however in the shape of the DPT (or often called the ‘Google tax’).
The political background to DPT can be discerned from its genesis at the Conservative party conference in October 2014. The taster given at the Autumn Statement led to much anticipation from the tax community keen to see how the UK government could unilaterally defeat the diversion of profits by multinationals out of the UK while at the same time heralding the multilateral approach under the...
