Substantial changes have been made to the profit fragmentation anti-avoidance since the original consultation was published. These rules apply to both individuals and corporates from April 2019. Businesses, including partnerships, with international aspects should consider whether they may apply and, if so, whether they need to take action. The key change from the government’s original proposal is that it now functions solely within self-assessment. The wider provisions for the need for taxpayers to notify HMRC that the rules could potentially apply, the need for payments on account and for HMRC counteraction have been removed.
