The International Tax Institute, Inc. holds monthly seminars in mid-town Manhattan on current subjects of international tax law.
We provide New York State continuing legal and professional education (non-transitional CLE and CPE) credits to international tax attorneys and accountants. Founded in 1961, we are a 501(c)(3) organization.
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Wednesday, May 27, 2015
The UK's recently enacted Diverted Profits Tax (widely referred to as the "Google tax") became effective April 1, 2015 and applies to large multinational enterprises which are considered to avoid UK corporate tax through contrived arrangements which lack economic substance or seek to avoid a UK permanent establishment. The rules are widely considered to be heavily targeted towards US multinationals that use perceived aggressive international structures (e.g. the “double Irish”) to reduce UK taxes.
The legislation is innovative and is considered to be a major step in the UK Government’s efforts to combat aggressive tax avoidance. Many consider, however, that the Diverted Profits Tax potentially has a wider application that was intended and, consequently, may be damaging to the UK’s previously stated aim of becoming the “most competitive tax regime in the G20."
How does the Divert Profits Tax directly impact US multinationals (how does it apply to common international arrangements and is it creditable for US tax purposes)? Will the Diverted Profits Tax achieve the UK Government’s aims? Is the UK diverging from the OECD's coordinated efforts to tackle base erosion and profit shifting ("BEPS") and, if so, will other countries follow the UK?
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