The author explains the draft legislation for the U.K.’s proposed diverted profits tax and analyzes the relationship of the provisions to the reforms under negotiation through the BEPS process of the G-20 and OECD. Although the official U.K. position is that the proposals are not out of line, they clearly go beyond what has been proposed so far in the BEPS project. Hence, they seem to be either an admission
that international agreement will not be reached that would satisfy U.K. concerns or
an attempt to put pressure on the negotiators to do so.