TY - JOUR

T1 - The UK's diverted profits tax

T2 - an admission of defeat or a pre-emptive strike?

AU - Picciotto, Sol

PY - 2015/1/19

Y1 - 2015/1/19

N2 - 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 admissionthat international agreement will not be reached that would satisfy U.K. concerns oran attempt to put pressure on the negotiators to do so.

AB - 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 admissionthat international agreement will not be reached that would satisfy U.K. concerns oran attempt to put pressure on the negotiators to do so.

KW - international corporate tax

M3 - Journal article

VL - 77

SP - 239

EP - 242

JO - Tax Notes International

JF - Tax Notes International

SN - 1058-3971

IS - 3

ER -