DIVERTED-PROFITS-TAX

HM Treasury has suggested that the government may narrow the notification requirements of, and widen the exclusion for loan relationships for, the proposed diverted profits tax (DPT).

Peter Cussons examines the potential EU law and international issues facing the UK's diverted profits tax.

In the first of a new series, Allan Cinnamon provides a global review of tax treaty developments, including the UK’s DPT.

Mark Middleditch (Allen & Overy) provides the monthly round-up of tax developments affecting the City

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

Hey, a new tax. As a tax adviser, that sounds like pretty good news. (Shame it is so bad for the country, but that's politics for you).

Commentary prepared by the Tolley tax team on the draft Finance Bill 2015 rules on:

• special purpose share schemes, with comment from Ashley Greenbank (Macfarlanes);
• diverted profits tax, with comment from Sandy Bhogal (Mayer Brown);
• investment managers and disguised fee income, with comment from Ben Eaton (Goodwin Procter);
• bank loss relief, with comment from Anna Anthony (EY).

It is clear that the government feels the need to ‘do something’. However, it is much less clear that the diverted profits tax proposals is the best thing to do, as Heather Self (Pinsent Masons) explains.