Draft clauses are published for the new diverted profits tax; while simple enough for a sound bite, the unfortunate business of having to write it down as law has clearly proved more challenging. Those brave enough to tackle the UK’s newest tax may well be left with more questions than answers. Clarification on the scope of the new withholding tax exemption for private placements, and the extent of its restrictions, is still needed. Another rethink on the financial products hallmark for DOTAS is promised in early 2015, and the OECD has published a further BEPS deliverable on interest deductions.
