2017 brings significant challenges for big business with the commencement of the anti-hybrids rules, a new corporate interest restriction and changes to the carried-forward loss regime. Tax rulings will face increased scrutiny as the European Commission pursues its state aid challenges and automatic exchange of information on cross-border tax rulings commences. On the plus side, there will be improvements to the substantial shareholding exemption and the reduction in the rate of corporation tax to 19%.
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