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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A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
April 22 2026
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