What are the likely tax developments to affect the City in the year ahead? asks Mark Middleditch (Allen & Overy).
BEPS: The UK is very much a ‘first responder’ on BEPS and a key development for 2016 will be turning BEPS theory into UK tax law. In particular the outcome of the consultation on the fixed ratio rule where there are so many variables to consider will determine the extent of limits on interest deductions in the UK. New legislation on hybrids is promised and its impact on regulatory capital will be of particular importance for the UK. Treaty changes and the multilateral instrument where the UK is also taking a lead will be of interest. There may be implications here for the diverted profits tax and how this is changing behaviour for multinationals operating in the UK will also...
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Home >Articles > Tax and the City: what can we expect for 2016?
Tax and the City: what can we expect for 2016?
What are the likely tax developments to affect the City in the year ahead? asks Mark Middleditch (Allen & Overy).
BEPS: The UK is very much a ‘first responder’ on BEPS and a key development for 2016 will be turning BEPS theory into UK tax law. In particular the outcome of the consultation on the fixed ratio rule where there are so many variables to consider will determine the extent of limits on interest deductions in the UK. New legislation on hybrids is promised and its impact on regulatory capital will be of particular importance for the UK. Treaty changes and the multilateral instrument where the UK is also taking a lead will be of interest. There may be implications here for the diverted profits tax and how this is changing behaviour for multinationals operating in the UK will also...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
