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Substantial changes have been made to the profit fragmentation anti-avoidance since the original consultation was published, writes Mark Saunders (PwC).

The draft provisions contain a number of measures related to enforcement and HMRC powers. Jason Collins (Pinsent Masons) takes a look.

The proposed new regime will not be as straightforward to apply in practice as HMRC suggests, writes Andrew Parkes (Milestone International Tax Partners). 

Kassim Meghjee and Helen Cox (Mishcon de Reya) review the government’s new proposals intended to take effect from next April.