HYBRIDS AND DIVERTED PROFITS

摘要

In his 2014 Autumn Statement the Chancellor made two announcements which are designed to combat international tax avoidance: a consultation document on hybrid mismatch arrangements and a diverted profits tax (DPT). The different approaches to what should fall under the same umbrella of combatting international avoidance are striking. DPT takes effect on 1 April 2015 with a limited consultation period and constitutes a unilateral action by the UK. However, the hybrid mismatch consultation builds on the OECD's Base Erosion and Profit Shifting (BEPS) work. Draft legislation is not expected until around 1 January 2017, giving business plenty of time to prepare.