The UK's diverted profits tax (DPT) was developed, and enacted, quickly in the weeks leading to the general election. The legislation was a two-pronged attack: on transactions having insufficient economic substance and the avoidance of permanent establishment (PE). The legislation went into effect April 1 2015 and there have been hints that other countries are looking at similar moves; but exactly what tax doctrines will other countries adopt to achieve similar objectives?
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Anticipating potential changes in tax basis interpretations can help reduce audit risks in tax planning for intercompany equity transfers, says Abe Zhao of FenXun partners
Sweeping changes are headed for Germany’s TP system in the New Year. Tax teams will need to be well-prepared, say Andreas Katz and Anna Kupprion of Kreston Bansbach