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?
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort