Substantial changes have been made to the profit fragmentation anti-avoidance since the original consultation was published, writes Mark Saunders (PwC).
On 17 January, the governments of the UK and Israel signed a protocol amending their 1962 double taxation convention.
The UK’s new double taxation agreements and protocol with Guernsey, signed in July 2018, entered into force on 7 January 2019.
The agreement and protocol take effect from: