The government has launched a consultation on the introduction of a fixed ratio rule to limit interest deductions in response to BEPS Action 4. While the detail is sketchy, some reform in this area now seems inevitable. Also on BEPS, there is a consultation on patent box reform, and the publication of draft regulations for country by country reporting. Extensive government amendments are made to the Summer Finance Bill at the report stage, including a new 45% withholding tax on restitution interest.
